Arnold Schwarzenegger 

Governor

RESTORATION SCALING AND THE 

HABITAT PRODUCTION FOREGONE 

METHOD

Prepared For: 

California Energy Commission 

Public Interest Energy Research Program 

Prepared By: 

Stratus Consulting Inc.

PIER

DRAFT 

PROJECT 

REPORT

 

PUBLICATION # 
Restoration to Offset Environmental Impacts 

of Coastal Power Plants 

Principal Investigator:

Elizabeth Strange, Managing Scientist 

Stratus Consulting Inc. 

Washington, DC 

Prepared for: 

The California Energy Commission 

Public Interest Energy Research (PIER) 

Melinda Dorin, Energy Commission Project Manager 

California Energy Commission Agreement #500-04-025 

Amount of agreement: $235,675 

San Jose State University Foundation Account No. 22-1509-3550-Stratus 

Publication Number: 

Publication date: 

Draft: January 29, 2008 
i 

Legal Notice 

This report was prepared as a result of work sponsored by the California Energy Commission 

(Energy Commission). It does not necessarily represent the views of the Energy Commission, its 

employees, or the State of California. The Energy Commission, the State of California, its 

employees, contractors, and subcontractors make no warranty, expressed or implied, and assume 

no legal liability for the information in this report; nor does any party represent that the use of 

this information will not infringe upon privately owned rights. This report has not been approved 

or disapproved by the Energy Commission nor has the Energy Commission passed upon the 

accuracy or adequacy of the information in this report. 

Acknowledgements 

This report was written by Dr. Elizabeth M. Strange, Principal Investigator (Managing Scientist, 

Stratus Consulting), Mr. David Allen (Vice President, Stratus Consulting), Mr. David Mills 

(Senior Analyst, Stratus Consulting), Mr. Dave Cacela (Senior Advisor), Ms. Colleen Donavan 

(Associate, Stratus Consulting), and Dr. Joshua Lipton (Chief Executive Officer, Stratus 

Consulting). 
ii

Abstract 

This report discusses ecological issues in determining the type and amount of restoration needed 

to offset losses of fishes from environmental impacts in California’s nearshore waters, with a 

focus on fish entrainment at coastal power plants that use once-through cooling. The report 

provides an overview of restoration scaling, evaluates the habitat production foregone (HPF) 

method that has been used to scale restoration in some power plant cases, and describes the data 

and methods needed to ensure reliable scaling results. Restoration scaling in this context is a 

quantitative technique, typically based on ecological metrics, for estimating the extent of habitat 

replacement needed to offset a given environmental loss. The scaling equation seeks to balance 

losses from an environmental injury with environmental gains from restoration. Analysis of the 

HPF method indicates that it is not necessarily a valid measure of the increase in fish production 

(the gain) expected from restoration, and therefore has important limitations as a scaling method. 

The report discusses conceptual and quantitative shortcomings of the HPF method that invalidate 

its use for many scaling purposes. The report concludes with a discussion of the elements 

required for a valid and reliable scaling approach, along with the data and methods used to 

implement such techniques. An attachment provides information on restoration actions to benefit 

particular species and the information needed for developing comprehensive restoration costs. 

Use of scientifically rigorous methods and targeted restoration monitoring to fill data gaps can 

greatly improve the ability of practitioners to reliably scale restoration, predict the ecological 

benefits of restoration, and monitor restoration success. 

Keywords: restoration, coastal restoration, fish restoration, restoration scaling, impingement and 

entrainment, cooling water intake structures, Clean Water Act section 316(b) 
iii

Preface 

The Public Interest Energy Research (PIER) Program supports public interest energy research 

and development that will help improve the quality of life in California by bringing 

environmentally safe, affordable, and reliable energy services and products to the marketplace. 

The PIER Program, managed by the Energy Commission, annually awards up to $62 million to 

conduct the most promising public interest energy research by partnering with Research, 

Development, and Demonstration (RD&D) organizations, including individuals, businesses, 

utilities, and public or private research institutions. 

PIER funding efforts are focused on the following six RD&D program areas: 

` Buildings Energy Efficiency End Use 

` Industrial/Agricultural/Water End-Use Energy Efficiency 

` Renewable Energy 

` Environmentally-Preferred Advanced Generation 

` Energy-Related Environmental Research 

` Energy Systems Integration. 

What follows is one of two final reports for California Energy Commission Agreement #500-04-

025, San Jose State University Foundation Account No. 22-1509-3550-Stratus, conducted by 

Stratus Consulting Inc. The report is entitled “Restoration to Offset Environmental Impacts of 

Coastal Power Plants.” This project contributes to the Water Intake Structure Environmental 

Research (WISER) program and the PIER Energy-Related Environmental Research program. 

For more information on the PIER Program, please visit the Energy Commission’s Web site at 

http://www.energy.ca.gov/research/index.html or contact the Energy Commission’s Publications 

Unit at 916-654-5200. 
iv

Executive Summary 

In some cases even the best technology available (BTA) cannot eliminate all environmental 

injuries that may result from power plant operation, and California permitting agencies may seek 

habitat restoration to offset losses that continue to occur even after technology implementation. 

Because of the continued importance of restoration in this and other contexts, California will 

need reliable methods to quantify the production of organisms in restored habitats, both to 

estimate the amount of restoration needed to offset losses and to determine restoration success. 

In this context, restoration scaling is a quantitative technique, typically based on ecological 

methods, for estimating the restoration gain needed to offset a given magnitude of loss. This 

report discusses restoration scaling as it applies to entrainment losses at coastal power plants that 

use once-through cooling. An evaluation of the habitat production foregone (HPF) method that 

has been used to scale restoration in some power plant cases indicates that it often is not a valid 

measure of the increase in fish production expected from restoration (the restoration gain). 

Comparison of HPF results with restoration estimates using appropriate scaling techniques 

indicate that the HPF method may significantly underestimate the amount of habitat restoration 

needed to offset a given magnitude of entrainment loss. This could be a serious problem whether 

or not restoration is actually implemented, because the costs associated with HPF restoration 

estimates are sometimes used in permitting and settlement negotiations about required 

technologies to minimize impingement and entrainment. This report provides a detailed 

discussion of the data and methods needed to conduct valid and reliable restoration scaling. The 

rate of fish production is not only an appropriate measure of the amount of restoration needed to 

offset a given loss, but it is also among the most useful metrics for monitoring restoration 

success. Use of scientifically rigorous methods and targeted restoration monitoring to fill data 

gaps can greatly improve the ability of practitioners to reliably scale restoration projects, predict 

the ecological benefits of restoration, and monitor restoration success. 

Project objectives were to: 

` Provide an overview of restoration scaling 

` Evaluate the HPF method as it has been used to scale restoration in California power 

plant studies 

` Recommend ways to improve the data and methods used for restoration scaling to offset 

entrainment losses 

` Provide information on restoration actions that may benefit California species vulnerable 

to entrainment 

` Identify the information needed to develop comprehensive estimates of restoration costs 

` Discuss the use of restoration costs in cost-effectiveness analysis 
v

` Develop recommendations for scientifically rigorous and robust techniques and 

additional data that can be used to improve the validity and reliability of restoration 

scaling. 

Key findings include: 

` When properly applied, restoration scaling can be an objective, quantitative, and 

transparent approach for determining the amount of restoration needed to offset 

impingement and entrainment losses. There is a substantial and growing literature on 

appropriate methods for conducting restoration scaling. 

` The HPF is often not a suitable scaling method because it typically does not adequately 

measure or estimate the increase in fish production (the gain) expected from restoration. 

Such a measure or estimate is necessary to reliably estimate the amount of restoration 

needed to achieve a gain sufficient to offset a given loss. 

` Appropriate restoration scaling metrics for fish include measures of recruitment, the 

addition of new recruits to the population per unit area per unit time, or productivity, the 

rate of biomass production per unit area per unit time. 

` The HPF often is not a reliable measure or estimate of recruitment or productivity. It is an 

estimate of the amount of habitat within a waterbody that could contain the quantity of 

larvae entrained based on the fraction of the larval population lost to entrainment 

mortality. For example, the HPF assumes that if 10% of the larval population is 

entrained, then these larvae must occupy the same fraction of the source water area 

(SWA) (i.e., 10% of the SWA). 

` This HPF assumption requires that organisms are uniformly distributed in the SWA and 

that the boundaries of the SWA and larval population can be clearly defined. These 

conditions are unlikely to be met except in closed or semi-enclosed water bodies. HPF 

estimates for entrainment at ocean power plants have significant uncertainty and this 

uncertainty will be difficult to overcome. 

` Comparison of HPF restoration scaling with results using more appropriate scaling 

metrics indicates that the HPF may significantly underestimate the scale of restoration 

needed to offset entrainment losses. 

Conclusions 

` The HPF method often does not provide an appropriate and reliable measure of the 

amount of restoration needed to offset a given magnitude of entrainment loss and should 

be used for this purpose only when site conditions justify the assumptions required in an 

HPF analysis. 

` Restoration scaling should be based on a measure or estimate of the increase in numbers 

or biomass of the species and life stages of concern in the restored habitat. 
vi

` Despite the appeal, and sometimes need, of relatively simple methods, more scientifically 

rigorous and robust restoration techniques are practical and would increase the likelihood 

of restoration success. 

` If unreliable scaling techniques are used, there is a serious risk of underestimating the 

amount and cost of restoration, resulting in a failure to achieve the expected mitigation of 

entrainment losses. 

Project recommendations include: 

` Limit use of the HPF method to estimating the amount of the SWA that is equivalent to 

the fraction of the larval population entrained. 

` Estimate the HPF for power plants located on bays and estuaries only. Estimates for 

power plants located on open coasts are too uncertain and unreliable to be useful, even 

with extensive analysis of larval dispersal and ocean currents. 

` Scale restoration based on a measure of the ecological benefits expected to result from a 

given restoration action. 

` Use the same metrics for restoration scaling and monitoring. 

` Conduct adaptive management of restoration activities to ensure that restoration goals are 

met. 

` Design restoration monitoring to collect data that can reduce scaling uncertainty. 

Project benefits 

The information provided in this report can benefit California regulators, facility operators, 

environmental stakeholders, and the Energy Commission in several ways. 

` Results provide guidelines for objective, scientifically-based, and transparent restoration 

scaling to address environmental impacts from power plants and other kinds of facilities, 

including hydropower facilities and desalination plants co-located with power plants. 

` Scientifically-rigorous restoration scaling methods, combined with ongoing restoration 

monitoring that will help fill data gaps, will greatly increase the likelihood of successful 

restoration actions. 

` Restoration costs based on valid restoration scaling make it possible to compare the costs 

to permit applicants of implementing technology to minimize losses with the costs to the 

public to mitigate losses absent the technology, which is directly relevant to licensing and 

permitting decisions about cost-effectiveness. 
vii

Table of Contents 

Abstract........................................................................................................................................... ii 

Preface............................................................................................................................................ iii 

Executive Summary....................................................................................................................... iv 

1. Introduction..........................................................................................................................1 

1.1 Background and Overview ......................................................................................1 

1.2 Project Objectives ....................................................................................................3 

1.3 Report Organization.................................................................................................3 

2. Project Approach .................................................................................................................4 

3. Project Outcomes.................................................................................................................5 

3.1 Background on Restoration Scaling........................................................................ 5 

3.2 The HPF Scaling Method........................................................................................ 6 

3.3 Evaluation of HPF Assumptions............................................................................. 7 

3.3.1 Assumption of habitat limitation ................................................................ 7 

3.3.2 Standing stock compared to rate of fish production ................................... 7 

3.3.3 Definition of the SWA................................................................................ 8 

3.3.4 Interpretation of PM.................................................................................... 9 

3.3.5 Habitat equivalency .................................................................................. 10 

3.3.6 Scaling based on averages ........................................................................ 11 

3.3.7 Discounting............................................................................................... 13 

3.4 Evaluation of HPF Analyses................................................................................. 14 

3.4.1 Moss Landing Power Plant ....................................................................... 14 

3.4.2 Morro Bay Power Plant ............................................................................ 18 

3.4.3 Diablo Canyon Power Plant...................................................................... 19 

3.4.4 Huntington Beach Generating Station ...................................................... 20 

3.4.5 Summary of omissions, biases, and uncertainties in HPF analyses.......... 21 

3.5 HPF Alternatives................................................................................................... 22 

3.5.1 Alternative scaling approach..................................................................... 22 

3.5.2 Developing estimates of fish production .................................................. 23 

3.5.3 Restoration monitoring and adaptive management................................... 29 

3.5.4 Guidelines for restoration scaling ............................................................. 30 

3.5.5 Recommended elements of a restoration proposal ................................... 30 

3.5.6 Scaling alternatives when species are not habitat-limited ....................... 30 

3.6 Use of Restoration Costs in Cost-Effectiveness and Cost-Benefit Analyses ....... 31 

3.6.1 Cost-effectiveness analysis ....................................................................... 31 

3.6.2 Cost-benefit analyses ................................................................................ 31 
viii

4. Conclusions and Recommendations ..................................................................................33 

4.1 Conclusions........................................................................................................... 33 

4.2 Recommendations................................................................................................. 34 

4.3 Benefits to California............................................................................................ 35 

References......................................................................................................................................36 

Glossary .........................................................................................................................................45 

List of Species................................................................................................................................47 

Attachment I. Restoration Actions and Restoration Costs.............................................................48 

Endnotes.........................................................................................................................................66 
ix

List of Figures 

1 The relationship between the size of SWA and the size of the replacement 

habitat (Ar) under different hypothetical scenarios in which values are varied 

for the habitat quality of the replacement habitat before (qb) and after 

restoration (qr) relative to that of the SWA (qi) ................................................................ 11 

2 Production flows to nekton from net annual marsh primary production.......................... 27 

List of Tables 

1 Hypothetical example illustrating variation in average PMs resulting from 

differences in the estimated size of the source areas used in the averaging ..................... 12 

2 Alternative HPF estimates of the scale of restoration using the different 

averaging scenarios provided in Table 1 .......................................................................... 12 

3 Summary of results of HPF analyses for four coastal power plants in California............ 15 

4 Summary of analysis of HPF assumptions for the MLPP, MBPP, DCPP, and HBGS .... 17 

5 Summary of omissions, biases, and uncertainties in HPF scaling.................................... 22 

6 Estimates from the published literature of rates of secondary production in 

coastal habitats.................................................................................................................. 29 
1 

1. Introduction 

1.1 Background and Overview 

Ecological restoration is increasingly recognized as one of the most important ways to protect 

natural resources from degradation and species loss as a result of human activities. The CALFED 

Program, for example, has spent nearly a half billion dollars in the past three years alone on 

habitat restoration actions to help restore the ecological health of the San Francisco Bay/Delta 

ecosystem (http://calwater.ca.gov/performancetracking/). 

Restoration can be particularly important when human activities that are necessary to promote 

human welfare harm ecological resources in ways that cannot always be prevented. For example, 

in some cases even the best technology available (BTA) cannot eliminate all environmental 

injuries that may result from power plant construction and operation, and permitting agencies 

may seek habitat restoration to offset injuries that may continue to occur even after technology 

implementation. 

The use of cooling water intake structures by California’s coastal power plants is a prominent 

example of a technical feature of power plant operation that may include residual impacts even 

after application of BTA. For the past several years, the U.S. Environmental Protection Agency 

(EPA) has been developing regulations to minimize the adverse environmental impacts of 

cooling water intake structures, pursuant to Section 316(b) of the federal Clean Water Act 

(CWA) (33 U.S.C. §1326). The State of California Water Quality Control Board and associated 

regional boards implement Section 316(b) under the federal National Pollutant Discharge 

Elimination System (NPDES) program. The California Energy Commission (Energy 

Commission) has authority for certifying any new or expanded facility with greater than 

50 megawatt (MW) capacity, pursuant to the 1974 Warren-Alquist Act (Public Resources Code 

Section 25000 et seq.). When these plants are in the coastal zone, the California Coastal 

Commission (CCC) has an important role in the review of re-powering projects. The Energy 

Commission must abide by CCC decisions unless they are infeasible or would result in greater 

harm to the environment. 

Section 316(b) of the federal CWA provides that: 

Any standard established pursuant to Section 1311 [CWA §301] or Section 1316 

[CWA §306] and applicable to a point source shall require that the location, 

design, construction, and capacity of cooling water intake structures reflect the 

best technology available for minimizing adverse environmental impact. 

EPA has interpreted Section 316(b) to mean that “adverse aquatic environmental impacts occur 

whenever there will be entrainment or impingement damage as a result of the operation of a 

specific cooling water intake structure” (U.S. EPA, 1977). As a cooling water intake structure 

withdraws water from local water bodies, organisms in the water column are trapped against 

intake screens (impingement) or drawn into the power plant’s cooling system (entrainment), 

resulting in losses of billions of organisms each year, mostly the eggs, larvae, and juveniles of 

estuarine and marine fishes. 
2

Despite the development of a number of mitigation technologies, such as screens across the 

openings of intake pipes, it has proven impossible to eliminate all of the organism losses that 

may occur as a result of intake structure operation. In particular, there are currently few 

technologies or operational measures for effectively reducing entrainment (U.S. EPA, 2004a). As 

a result, habitat restoration has been considered as a means to offset unavoidable losses. 

Although the courts have ruled that restoration is not a technology for the purpose of determining 

BTA under Section 316(b), both the California Coastal Act (CCA) and the California 

Environmental Quality Act (CEQA) include provisions for restoration as a means of protecting 

California’s natural resources: 

` The CCA requires that marine resources be maintained, enhanced, and, where feasible, 

restored (Section 30230), and that the biological productivity and the quality of coastal 

waters, streams, wetlands, estuaries, and lakes be maintained and, where feasible, 

restored (Section 30231). 

` CEQA considers a variety of measures, including avoiding impacts; minimizing impacts; 

rectifying the impact by repairing, rehabilitating, or restoring the impacted environment; 

reducing or eliminating the impact by preservation and maintenance; and compensating 

for the impact by replacing or providing substitute resources or environments. 

In addition, entrainment often occurs even with the implementation of BTA. Thus, irrespective 

of national Section 316(b) regulations, California licensing and permitting agencies may 

continue to require restoration as a means to offset impingement and entrainment losses that may 

continue to occur even after implementation of BTA. Furthermore, the cost of sufficient 

restoration to offset entrainment and impingement that would occur with different technology 

alternatives can be an important element in evaluating which technology to require at a given 

facility, where different alternatives may fit within the definition of BTA. 

Because of the continued importance of restoration in this and other contexts, California will 

need reliable methods to quantify the production of organisms in restored habitats, both to 

estimate the amount of restoration needed to offset losses and to determine restoration success 

where restoration is actually implemented. Restoration scaling can use ecological metrics to 

develop such estimates, and is the focus of this report. “Scale” refers to the spatial and temporal 

extent of a restoration action, and “restoration scaling” involves the process of determining the 

scale of restoration by balancing restoration gains with resource losses. Restoration scaling can 

be used to evaluate the type and amount of harm caused by a given environmental impact, the 

type and amount of benefit resulting from restoration, and the equivalency of restoration gains 

compared to environmental losses. 
3

1.2 Project Objectives 

The overall objective of this project was to consider key ecological issues in determining the 

type, amount, and cost of restoration needed to offset losses of estuarine and marine fishes from 

environmental impacts in California’s nearshore waters, with a focus on entrainment losses from 

the operation of power plant cooling water intake structures. 

Specific objectives were to: 

` Provide an overview of restoration scaling 

` Evaluate the habitat production foregone (HPF) method as it has been used to scale 

restoration in California power plant studies 

` Recommend ways to improve the data and methods used for restoration scaling to offset 

entrainment losses 

` Provide information on restoration actions that may benefit California species vulnerable 

to entrainment 

` Identify the information needed to develop comprehensive estimates of restoration costs 

` Discuss the use of restoration costs in cost-effectiveness analysis 

` Develop recommendations for scientifically rigorous and robust techniques and 

additional data that can be used to improve the validity and reliability of restoration 

scaling. 

1.3 Report Organization 

This report provides an overview of restoration scaling and evaluates the HPF method. Our 

review of the HPF method includes an in-depth discussion of specific assumptions of the HPF 

method, an evaluation of HPF analyses conducted to date, and ways to develop a more 

scientifically-rigorous and reliable scaling technique. This material is followed by a discussion of 

the use of restoration costs for cost-effectiveness analysis. The report includes an attachment that 

provides suggestions for restoration actions for particular species and information needed to 

develop comprehensive restoration cost estimates. This material is organized into the following 

sections: 

` Section 2 outlines the project approach 

` Section 3 discusses project outcomes, including background on restoration scaling 

(Section 3.1); a description of the HPF method (Section 3.2); an evaluation of the 

main assumptions of the HPF (Section 3.3); a review of HPF studies as of 2007 

(Section 3.4); recommendations for ways to improve restoration scaling 
4

(Section 3.5); and the use of restoration costs for cost-effectiveness evaluations 

(Section 3.6) 

` Section 4 provides conclusions and recommendations for how the Energy 

Commission can use project results to conduct restoration scaling, evaluate 

restoration proposals, and increase the likelihood of successful restoration actions. 

2. Project Approach 

Documents on the HPF were assembled and reviewed for appropriateness of assumptions, data, 

methods, and interpretation of results. There is no single document that provides a 

comprehensive description of the HPF method. For this review, we considered information found 

in parts of several documents and presentations, including: Duke Energy (2000); CCRWQCB 

(2004); CEC (2005); Foster (2005); Raimondi et al. (2005); Appendix C of York and Foster 

(2005); Raimondi (2005, 2006a, 2006b); Davis et al. (2006a, 2006b); Steinbeck (2006a, 2006b); 

and Steinbeck et al. (2007). 

We also reviewed individual HPF analyses for four power plants (Moss Landing, Morro Bay, 

Diablo Canyon, Huntington Beach) to assess the basis for and validity of their restoration 

estimates. The entrainment studies and modeling results underlying the HPF analyses were also 

reviewed: Moss Landing (Tenera, 2000b); Morro Bay (Tenera, 2001); Diablo Canyon (Tenera, 

2000a) Huntington Beach (MBC Applied Environmental Sciences and Tenera Environmental, 

2005). In addition, we examined relevant Energy Commission decisions, facility compliance 

documents, and other unpublished reports. We analyzed this information by reference to the 

scientific literature on restoration scaling. 

We also reviewed relevant portions of recent analyses of the environmental implications of oncethrough cooling by the Energy Commission (York and Foster, 2005), fisheries scientists with 

experience in conducting entrainment studies and HPF analyses (Steinbeck et al., 2007), and the 

Electric Power Research Institute (EPRI, 2007). 

To identify species-specific restoration actions, we contacted local biologists for their 

recommendations about restoration activities that could benefit the species of concern and 

examined the relevant published and unpublished documents on the ecology of the species. For 

restoration costing information, we contacted local restoration experts for estimates of costs 

associated with planning, implementing, and monitoring restoration. All sources are cited in the 

main report, with complete citations for all referenced documents provided in the reference list at 

the end of the report.
5

3. Project Outcomes 

3.1 Background on Restoration Scaling 

Restoration scaling begins by expressing losses and gains in equivalent units, and then 

establishes a scaling equation with losses on one side and restoration gains on the other. The 

scaling exercise adjusts the amount of restoration until the equation balances future gains with 

past (and ongoing) losses (NOAA, 1997; Ofiara, 2002; Allen et al., 2005a). 

Many restoration scaling techniques originated in the context of natural resource damage 

assessments (NRDAs). They were designed to assist in the assessment of damages resulting from 

natural resource injuries that can be difficult to value using a monetary currency of exchange. In 

economics, value is based on the concepts of preferences and tradeoffs. The use of ecological 

metrics for restoration scaling makes it possible to express preferences and tradeoffs in terms of 

an ecological rather than a monetary currency of exchange (Freeman, 1993; Kopp and Smith, 

1993; NOAA, 1997; Ofiara, 2002). 

Three categories of scaling techniques that have been devised to evaluate equivalence among 

restoration losses and gains include resource-to-resource, service-to-service, and value-to-value 

scaling. When the number of organisms (or other resource unit) lost and gained can be measured, 

a resource equivalency analysis (REA) can be conducted using resource-to-resource scaling. 

Here, the primary challenge is to differentiate organism losses and gains through time from 

fluctuations in biological populations that result from other factors such as natural environmental 

variation, immigration, emigration, interactions among species, and other ecological constraints 

(Allen et al., 2005a). 

If the injury is to habitat, and it is possible to measure both the area of habitat lost and the area of 

habitat needed to offset the loss, then a habitat equivalency analysis (HEA) is an appropriate 

scaling technique. In practice, most HEAs involve the measurement of one or more natural 

resource “services” in a process known as service-to-service scaling. NOAA (2006) has 

distinguished two types of services: human use services, which are those services that natural 

resources provide to people (e.g., surface waters provide drinking water); and ecological 

services, the services that one natural resource provides another natural resource (e.g., wetlands 

provide nursery habitat for fish) (Allen et al., 2005a), which are assumed to be valued by the 

public. 

Value-to-value scaling focuses on the value (i.e., benefits or satisfaction) that people derive from 

natural resources, where values can be compared or measured without conversion to dollars. This 

type of analysis, known as value equivalency analysis (VEA), is useful when it is not possible to 

restore exactly the same services as those lost, but it is possible to identify equally valued 

alternative services for restoration (Allen et al., 2005a; Lazo et al., 2005). 
6

3.2 The HPF Scaling Method 

The first step in an HPF analysis seeks to represent entrainment losses in terms of habitat area. 

This is accomplished by conducting source water sampling of larvae and using an entrainment 

assessment method known as the Empirical Transport Model (ETM) to estimate the proportional 

mortality (PM) of larvae in the source water area (SWA) due to entrainment (Steinbeck et al., 

2007).1

For enclosed or semi-enclosed water bodies, the SWA has been determined using methods such 

as geographic information system (GIS) and habitat data layers from the National Wetlands 

Inventory and other sources. 

For open coast species, the approximate boundaries of the SWA and larval populations are 

difficult to determine. Estimates are developed by considering the alongshore distance over 

which larvae vulnerable to entrainment may disperse to the intake. This is determined by 

considering the period of larval duration and the distance along the coast those larvae could have 

traveled during that time, which is measured by the net current displacement (i.e., the distance 

water could have traveled during that time). The alongshore length of the SWA is then 

determined by multiplying the period of larval duration by the net current displacement. This 

length is multiplied by a constant for offshore distance (the width of the area of plankton 

sampling) to determine the SWA (Steinbeck et al., 2007). 

By multiplying the SWA by the PM, the area within the SWA containing the quantity of larvae 

entrained (the so-called HPF or area production foregone) is determined as follows: 

A = PM Η SWA (Equation 1) 

where: 

A is the estimated area containing the quantity of larvae entrained (i.e., the 

HPF estimate). 

For example, if the PM is 25% (i.e., 25% of the larval population in the SWA is entrained) and 

the SWA is 2,000 acres, then the HPF assumes that 25% of 2,000 acres is the amount of habitat 

represented by the entrainment loss. In this example, the estimate is 500 acres.2

The second part of an HPF analysis assumes that this HPF estimate also gives the amount of 

replacement habitat needed to produce organisms at a level sufficient to offset the entrainment 

loss. This step is problematic for several reasons, particularly because it implicitly equates larval 

standing stock in the SWA (i.e., entrained fish per unit area) with fish productivity (i.e., fish 

production per unit area per unit time). For this to be a valid approximation, a number of 

important conditions must be met, as discussed in the following section. 
7

3.3 Evaluation of HPF Assumptions 

If the PM is used as a straight multiplier to determine the amount of replacement habitat 

(i.e., PM × SWA = HPF = area of replacement habitat), the SWA must have the following 

characteristics in order to serve as a valid estimate of the area of replacement habitat needed to 

increase larval production to the level needed to offset entrainment losses: 

` The replacement habitat and the SWA must have very similar species (and species mix), 

age distributions, and immigration/emigration relationships. 

` The replacement habitat must have very similar productive capacity as the SWA (i.e., the 

rate of larval production in the replacement habitat, on an aerial basis, must be equivalent 

to the rate of larval production in the SWA). 

` The replacement habitat must be capable of producing an increase in larval production 

above the baseline production that would be achieved in that habitat absent the 

restoration actions. (Note that preservation alone will only yield an increase production if 

losses of those habitats can be reasonably expected without preservation.) 

` The replacement habitat probably must be in a different location from the affected SWA 

to avoid offsetting any increase by exposing the larvae to entrainment. 

Below we discuss a number of issues related to these assumptions. 

3.3.1 Assumption of habitat limitation 

The HPF method implicitly assumes that entrained species are limited by the production of 

larvae and that larval production is limited by habitat. However, there are numerous factors that 

can limit fish populations, and the assumption that production is habitat-limited may not hold for 

all species or life stages. For example, local populations of fishery species may be limited by 

fishing mortality on adults, or larvae may be limited by food availability. If such factors are 

limiting populations of entrained species, then restoration of larval habitat may do little to 

increase recruitment and offset entrainment losses, even though restoration may be beneficial to 

the environment in general. 

3.3.2 Standing stock compared to rate of fish production 

The HPF approach implicitly assumes that there will be an increase in the numbers or biomass of 

entrained fish in a replacement habitat based on knowledge of larval standing stock (i.e., the PM 

and HPF are referenced to larval density in the SWA). However, standing stock is a measure of 

fish per unit area at a single point of time, not a measure of the rate of change in fish production 

(fish produced per unit area per unit time). For restoration scaling, the appropriate unit of 

comparison includes both area and time (NOAA, 1997). 
8

Even if habitat limitation is found to be a factor for species of concern, habitat restoration will 

only augment larval production if baseline conditions in the replacement habitat are suppressing 

current production. The goal of restoration is to increase baseline production in a replacement 

habitat at a scale that will augment production sufficiently to offset losses. Therefore, restoration 

scaling requires measures of recruitment (the addition of new recruits to the population per unit 

time) or productivity (the rate of biomass production per unit time). The density of organisms in 

the water column is a measure of standing stock, which may not correlate with recruitment or 

productivity. 

Standing stock refers to the abundance or biomass of organisms within a unit area at a single 

instant in time, and is therefore not a measure of population change. In fact, species with the 

same standing stock may have very different rates of production. For example, a population of 

large, slow-growing individuals with low productivity could have the same standing stock as a 

population of small, fast-growing individuals with high productivity. 

Standing stock can be used to estimate productivity only if: (1) those individuals observed at the 

time of abundance sampling are all the individuals of the age sampled that will be produced that 

year, (2) there is no turnover, and (3) there is no immigration or emigration. Abundance may be 

less than production if there is immigration, multiple spawning bouts not covered by the 

sampling regime, or sampling inefficiency (including gear inefficiency or failure to adequately 

sample a patchy habitat). Abundance may be greater than production if there is emigration. 

3.3.3 Definition of the SWA 

For HPF results to be valid, the SWA must meet the following conditions: 

` The SWA must comprise relatively uniform habitat with organisms evenly distributed in 

the SWA 

` The larval population in the SWA must be a closed or semi-enclosed population or the 

aerial extent of the SWA and the distance and timing of larval dispersal into the area must 

be known. 

There are realistic circumstances that can violate these assumptions. For example, the aerial 

extent of the SWA may be too difficult to determine reliably if the hydrodynamics of the SWA 

and the zone of influence of the intake are too complex to determine larval dispersal, such as 

when intakes are located on oceans or waters connected to an ocean that are subject to strong 

currents or tidal influences (Steinbeck et al., 2007). 

A highly variable PM over time could indicate that larvae in the SWA are fluctuating differently 

than the larvae being entrained, which could indicate inadequate understanding of 

hydrodynamics or larval dispersal distances. 
9

3.3.4 Interpretation of PM 

The PM is difficult to interpret without knowledge of absolute losses and the extent of the SWA. 

PM estimates have been found to be very small for wide-ranging species with a large SWA, such 

as northern anchovy and other small pelagic species, or as high as 50% for larvae spawned near 

power plants with a smaller SWA (Steinbeck et al., 2007). It is not necessarily true, however, 

that a small PM represents a large impact and a high PM represents a high impact. A species 

with a small PM in a small area will obviously experience a larger impact than a wide-ranging 

species with the same PM. Likewise, a species with a large PM and a large population area 

relative to the SWA may experience a relatively minor impact compared to a species with the 

same PM in a small, confined area that represents most of the SWA and the area containing the 

population (Steinbeck et al., 2007). 

Where larvae are distributed over long distances, such as along open coasts where the ratio of 

cooling water volume to source water volume is low, proportional losses may appear small even 

though absolute losses are high (Steinbeck et al., 2007). On the one hand, this could be 

interpreted as meaning that losses are insignificant because a low PM means that only a small 

fraction of the total larval population is lost. On the other hand, if the permitting focus is to 

minimize entrainment, then absolute loss is the endpoint of interest, and the fraction of larvae 

lost is not as relevant. 

More importantly, although the PM indicates the fraction of the larvae entrained, this loss is to 

the current generation only. The PM does not provide an assessment of the reproductive potential 

of the adult spawning stock, and therefore it does not inform the question of population 

sustainability or ecological significance. 

Because of difficulties developing and interpreting fractional loss models like the ETM and 

population-level assessments, EPA has interpreted Section 316(b) to mean that “adverse aquatic 

environmental impacts occur whenever there will be entrainment or impingement damage as a 

result of the operation of a specific cooling water intake structure” (U.S. EPA, 1977). EPA has 

focused on entrainment loss because it is the most direct measure of impact and is the measure 

with the least uncertainty. 

Entrainment assessments focusing on higher levels of biological organization (such as the ETM 

fractional loss model) involve significantly more data collection, as well as more uncertainty, 

than the direct measure of entrainment at the intake (see EPRI, 1999, for a description of the 

wide variety of assessment methods available, including data needs and uncertainties). 

For example, the following data from the ETM are required to implement the HPF method using 

PM as a scaling metric: 

` Total number of larvae entrained (parameter E in the ETM) 

` Larval density and abundance in the affected area (parameters ρ and N in the ETM) 

` Proportion of sampled source water to total source water (parameter Ps in the ETM). 
10

Of these various inputs, only the total number of larvae entrained can be measured directly with 

relatively minimal uncertainty and without ecological assumptions. 

3.3.5 Habitat equivalency 

The HPF approach does not examine equivalence directly, but implicitly assumes that all acres 

of habitat producing entrained organisms and being restored are equal with a simple one-to-one 

relationship, on an areal basis, between losses and gains. However, the method establishes a 

balancing equation based on different types of habitat, defining losses in units of wetted area and 

gains in units of nearshore habitats that produce larvae. 

Moreover, it is almost never the case that the ecological quality of a restored habitat is 

comparable to that of the original habitat (Strange et al., 2002). In fact, a recent review of fish 

habitat restoration projects in Canada found that even use of a mitigation ratio of 2:1 was not 

sufficient to ensure “no net loss” for all projects (Quigley and Harper, 2006). 

Another complicating factor is that the habitat targeted for restoration, regardless of quality, may 

currently support some “baseline” amount of fish production. In such cases, the restoration gains 

must be assessed as the incremental change in quality, not simply the quality after restoration 

(NOAA, 2006). 

The implications of habitat differences for the scale of restoration can be illustrated using a 

generalization of the basic HPF method that accounts for quality differences, expressed as: 

Ar = (PM × SWA) × qi / (qr – qb) (Equation 2) 

where: 

Ar is the area of restored habitat 

PM is the PM in the SWA 

SWA is the area containing larvae at risk of entrainment 

qi is the relative habitat quality within the SWA 

qr is the relative habitat quality of the Ar after restoration 

qb is the relative habitat quality of the Ar before restoration. 

Figure 1 is a graphical representation of some different habitat quality scenarios.

Our formulation allows for the unlikely possibility that restored habitat is superior to the habitat 

of the SWA (qr > qi). More likely are situations where restored habitat is inferior to the habitat of 

the SWA (qr < qi). In such cases, the area needed for restoration will be larger [Ar > (PM × 

SWA)] than that calculated by the HPF [Ar = (PM × SWA)]. 
11

In one recent case (Huntington Beach), resource agencies have considered addressing potential 

inequalities among habitats using so-called “mitigation ratios” or “conversion factors.” 

Mitigation ratios were originally devised to ensure that wetland mitigation activities achieved the 

goal of “no net loss” of wetland area and services. The purpose of mitigation ratios is to help 

achieve an appropriate scale of restoration when wetland habitats differ in type or quality or 

when there are significant uncertainties about habitat productivity. However, if such ratios are 

selected without a formal analysis using available ecological information, uncertainties about 

whether proposed restoration will offset entrainment losses will not be resolved. In such cases, 

the results of restoration monitoring are necessary to determine appropriate ratios and potential 

adjustments in the amount of restoration. 

3.3.6 Scaling based on averages 

The HPF scales restoration based on the average SWA and the average PM for the species of 

concern. An argument presented in favor of averaging is that each taxon can be considered an 

independent sample from the collection of all taxa that are entrained, and therefore the mean of 

several of these samples can be used to represent the loss rate for all entrained taxa (Steinbeck 

et al., 2007). In addition, the assumption is made that the estimate of impact becomes more 

reliable with increasing sample size (i.e., the number of species evaluated) (Davis et al., 2006b). 

0.00

5.00

10.00

15.00

20.00

25.00

30.00

35.00

40.00

0.00 10.00 20.00 30.00 40.00 50.00 60.00 70.00 80.00

SWA area

Ar (area to restore)_

PM = 20%; qr = 0.5 qi; qb = 0.1 qi

PM = 20%; qr = 0.5 qi; qb = 0

PM = 20%; qr = qi; qb = 0.1 qi

PM = 20%; qi = qr; qb = 0

PM = 20%; qr = 1.5 qi; qb = 0

Figure 1. The relationship between the size of SWA and the size of the replacement 

habitat (Ar) under different hypothetical scenarios in which values are varied for the 

habitat quality of the replacement habitat before (qb) and after restoration (qr) relative 

to that of the SWA (qi). 
12

However, the average PM is difficult to interpret when the size of the SWA differs by species. 

The situation is analogous to the problem of averaging several ratios when the denominators are 

different. This kind of averaging strongly influences HPF estimates of the area of replacement 

habitat needed to offset losses. 

This problem is illustrated in Table 1 for a simple hypothetical example for two species, where 

the respective populations do not increase in the same proportion as the size of the SWA, such as 

when a species depends on a specific habitat that is not uniformly distributed in a region. 

Table 1. Hypothetical example illustrating variation in average PMs resulting from 

differences in the estimated size of the source areas used in the averaging 

Fish 

species 

Estimated 

larvae in a 

10 km2

 area 

Estimated 

larvae in a 

50 km2 area 

Larvae lost to 

entrainment in 

sampling period 

PM 

assuming a 10 km2

source area 

PM assuming a 

50 km2 source 

area 

A 1,000 2,000 500 50% 25% 

B 2,000 10,000 1,000 50% 10% 

PM averaging method Average PM 

Average PM assuming a 10 km2 source area for both Species A and Species B 50.0% 

Average PM assuming a 50 km2 source area for both Species A and Species B 17.5% 

Average PM assuming a 50 km2

 source area for Species A and a 10 km2 area for Species B 37.5% 

Average PM assuming a 10 km2

 source area for Species A and a 50 km2 area for Species B 30.0% 

Specifically, assume that Species A and Species B are both entrained by the intakes of power 

plant Y, and they have different larval population sizes (that vary differently between species as 

SWA size increases) and different entrainment rates. If the PMs for the two species are 

calculated on the basis of an estimated source area of 10 km2

, then the PM for both species is 

50% (see Table 2). If these PMs are averaged, then the average PM is also 50%. If instead, the 

SWA for both species is estimated as 50 km2

, then the calculated PM for Species A is 25%, 

while the calculated PM for Species B is 10% (see Table 1). In this case, the average of the PMs 

is only 17.25%. 

Table 2. Alternative HPF estimates of the scale of restoration using the different averaging 

scenarios provided in Table 1 

PM calculation 

Average 

PM 

Average 

source area 

HPF 

(average PM × 

average source area)

Average PM assuming a 10 km2 source area 50.0% 10 km2 5.00 km2

Average PM assuming a 50 km2 source area 17.5% 50 km2 8.75 km2

Average PM assuming a 50 km2 source area 

for Species A and a 10 km2

 source area for 

Species B 

37.5% 30 km2 

(average of the 10 km2 and 

50 km2

 source areas) 

11.25 km2

Average PM assuming a 10 km2 source area 

for Species A and a 50 km2

 source area for 

Species B 

30.0% 30 km2 

(average of the 10 km2 and 

50 km2

 source areas) 

9.00 km2
13

Now consider what happens to the average PM when the estimated SWAs for the two species are 

different. If the PM of Species A is 25% based on an estimated SWA of 50 km2

, and the PM of 

Species B is 50% based on an estimated SWA of 10 km2, then the average PM is 37.5%. But if 

the PM of Species A is 50% based on a 10 km2

 SWA, while the PM of Species B is 10% based 

on a 50 km2 SWA, then the average is only 30%. 

Thus, the PM calculation is very sensitive to the size of the SWA, and therefore to the 

assumptions that are used to estimate the SWA. In turn, the effects of the size of the SWA, on the 

PM and average PM, influences the results of the restoration scaling. Using the information in 

Table 1, Table 2 shows that the scale of restoration to offset the entrainment of Species A and 

Species B will vary from 5 to 11 km2 depending on estimates of the average PM and the average 

SWA. 

Another consequence of averaging is that the amount of restoration may be insufficient to offset 

the losses of any species requiring more habitat than the average. This is one reason that the scale 

of restoration is often based on the species requiring the maximum amount of restoration 

(e.g., Strange et al., 2004a, 2004b; Allen et al., 2005b). 

In most cases it will be important to account for all species losses individually, particularly if 

there is significant variation in their habitat requirements, life history, or other characteristics 

such as rarity (e.g., threatened and endangered species). In fact, it is often argued that all species 

should be included in loss estimates, particularly when the assessment is part of a cost-benefit 

analysis (e.g., Suter, 2005). 

3.3.7 Discounting 

The HPF method does not incorporate discounting, which is common practice in restoration 

scaling and which is required when integrating restorations gains over time for comparison with 

losses over time. Both the loss and gain side of a scaling equation are discounted to express 

results in terms of a common year. This makes it possible to compare the timing and duration of 

losses with the predicted timing and trajectory of restoration gains (Julius, 1999; NOAA, 1999). 

In addition to accounting for lags between the timing of loss and recovery, discounting converts 

losses and gains into “present value equivalents.” This is done to account for the fact that gains 

in fish production in the future as a result of restoration are less valuable to the public than fish 

available now, much in the way a dollar now is worth more than a dollar later. 

The discount factor is: 

(1 + d)

y

 (Equation 3) 

where: 

d is the discount rate and y is the years before or after entrainment 

y is the years before or after entrainment, calculated as y = year of entrainment – year of 

interest. 
14

For example, to account for the delay between the time of entrainment loss and the time that 

restoration achieves the targeted level of fish production, discounting is used to express the total 

value of restoration gains over all years (TV) in terms of the year of the loss: 

y TV = ∑ V y [1 / (1 + d )] (Equation 4) 

where: 

Vy is the value y years after the loss. The National Oceanic and Atmospheric 

Administration (NOAA) and other resource agencies typically use a discount rate of 3% 

for discounting public resources and values (Julius, 1999; NOAA, 1999). 

3.4 Evaluation of HPF Analyses 

The HPF method has been used to estimate the scale of restoration needed to offset entrainment 

losses at Moss Landing, Morro Bay, Diablo Canyon, and Huntington Beach. Table 3 summarizes 

the results of HPF analyses for the four power plants, followed by an evaluation of the analyses 

in terms of the issues outlined in Section 3.3. 

3.4.1 Moss Landing Power Plant 

The HPF method was first used for the Moss Landing Power Plant (MLPP) modernization 

project. The MLPP is located near Moss Landing Harbor, about 12 miles northwest of the Town 

of Salina on the Central Coast of California, adjacent to Monterey Bay. In 1999, the facility 

operator proposed to modernize the facility. Units 1-5 of the facility’s seven generating units 

were retired in 1995. The proposed modernization added two, 530 MW, natural gas-fired, 

combined cycle units that utilized the intake system of the retired units and the discharge 

structure for Units 6 and 7. In addition, Units 6 and 7 were upgraded by 73 MW. Combined, the 

new units and Units 6 and 7 use about 850 million gallons per day (MGD) of seawater for 

cooling (Duke Energy, 2000). 

The organisms entrained were assumed to use Elkhorn Slough as their primary habitat. Elkhorn 

Slough is a protected area north of the MLPP with tidal marshes, mudflats, and shallow open 

water habitat. Eight “target taxa” (i.e., the most abundant species/taxa in entrainment samples) 

included unidentified gobies, bay goby, blackeye goby, longjaw mudsucker, blennies, Pacific 

herring, white croaker, and Pacific staghorn sculpin. These species made up 95% of all entrained 

larvae collected in entrainment sampling, and were considered “proxy species” for all entrained 

species (Tenera, 2000b). 
15

Table 3. Summary of results of HPF analyses for four coastal power plants in California

Power plant 

Annual entrainment of fish species 

included in HPF estimate (rounded)

PMAVG for fish 

species included in 

HPF analysis (%) 

SWA used for 

HPF analysis 

Amount of restoration 

estimated by HPF 

Moss Landinga All target species: 

Unidentified gobies – 2.7 × 108 Bay goby – 1.5 × 108 Blackeye goby – 1.7 × 107 Longjaw mudsucker – 8.0 × 106 Blennies – 1.7 × 107 Pacific herring – 4.4 × 106 White croaker – 8.6 × 106 Pacific staghorn sculpin – 8.6 × 106

13% 3,000 acres 390 wetland acres 

Morro Bay b Bay species only: 

Unidentified gobies – 3.9 × 108 Shadow goby – 1.3 × 107 Combtooth blennies – 1.0 × 107 Jacksmelt – 6.3 × 106 Pacific herring – 3.0 × 106

33% 2,300 acres 759 acres 

Diablo Canyonc Rocky reef fishes only: 

Smoothhead sculpin – 8.6 × 107 Monkeyface prickleback – 7.2 × 107 Clinid kelpfishes – 2.4 × 108 Blackeye goby – 1.2 × 108 Cabezon – 4.4 × 107 Snubnose sculpin – 9.7 × 107 Painted greenling – 1.7 × 107 KGB rockfishes – 2.5 × 108 Blue rockfish – 5.9 × 107

10.76% Not reported in 

HPF document 

reviewed 

200-1,000 acres 

artificial reef
16

Table 3. Summary of results of HPF analyses for four coastal power plants in California (cont.)

Power plant 

Annual entrainment of fish species 

included in HPF estimate 

PMAVG for fish 

species included in 

HPF analysis (%) 

SWA used for 

HPF analysis 

Amount of restoration 

estimated by HPF 

Huntington Beachd Soft bottom species only: Spotfin croaker – 7.0 × 106 

Queenfish – 1.8 × 106 White croaker – 1.8 × 106 Black croaker – 7.1 × 105 Blennies – 7.2 × 105 Diamond turbot – 5.4 × 105 California halibut – 5.0 × 105 Rock crab – 6.4 × 105

0.56% Three estimates of 

the SWA reported: 

0.11 km2, 4.47 km2, 

and an average of 

1.50 km2. Area used 

for Energy 

Commission HPF 

estimate not given 

in document 

reviewed. 

208 wetland acres 

(all units), 104 acres 

(Units 3 and 4)

a. From Table 3 and accompanying text by Dr. Pete Raimondi, University of California at Santa Cruz, in Strange et al. (2004a) b(2000b). PM and HPF estimates were based on the estimated average period that larvae are at risk of entrainment. b. From CCRWQCB (2004). PM and HPF estimates were based on estimated maximum period larvae are at risk. Coastal taxa (s

northern lampfish, rockfishes, white croaker, cabezon) had a PMAVG of 3% and were not included in the HPF analysis. Estimated 

Bay Estuary. Restoration cost was based on an estimated cost of $37,000 per acre developed by staff of the Central Coast RegionControl Board and the Morro Bay National Estuary Program, assuming restoration costs of $26,000 per acre and an average purcfloodplain habitat of $11,000 acre. c. From Raimondi et al. (2005). Restoration cost is based on an estimated cost of $50,000 per acre based on costing information fArtificial Reef (SCAR). Entrainment estimates are average of sampling periods 1 (1996-1997) and 2 (1997-1998) from Table 1 o(2005). Sampling period 3 overlapped period 2 and therefore was not included in the entrainment estimates. d. HPF estimates are from Biology Table 2 of Davis et al. (2006b), included with California Energy Commission’s Order RequirStudies, posted online 10/4/2006 at http://energy.ca.gov/sitingcases/huntingtonbeach/compliance/index.html. Estimates in table w

flow of 507 MGD. Restoration cost was based on an estimate of $74,660 per acre for initial restoration costs and $784 per acre fomaintenance provided by restoration experts working on the Huntington Beach Wetlands. Final Energy Commission decision waoperational flow of 235.5 MGD for Units 3 and 4, and required 66.8 acres and $5,511,000. Analysts die not include two target taanchovies, in the HPF analysis, because they argued that gobies do not occur near Huntington Beach Generating Station (HBGS) anchovies occur over a much larger area than the nearshore SWA (Davis et al., 2006b). 
17

Restoration scaling using the HPF method was based on the PMAVG for the eight target species, 

which was 13% based on the average period that larvae were considered at risk of entrainment, 

and 28% based on the maximum potential period at risk. From GIS mapping, analysts concluded 

that there were 3,000 acres of relatively enclosed aquatic habitat in Elkhorn Slough that are 

subject to inundation and therefore could support the organisms subject to entrainment. This area 

was considered the SWA. Using this SWA estimate and the two PM estimates, the HPF analysis 

estimated that the amount of restoration needed to offset entrainment at MLPP was between 

390 acres (13% × 3,000 acres) and 840 acres (28% × 3,000 acres). 

The final negotiated settlement was for restoration of 390 acres at an estimated cost of 

$7,000,000 (Energy Resources and Conservation and Development Commission, 2000). 

As summarized in Table 4, the HPF analysis for the MLPP meets some critical assumptions for 

HPF validity. Specifically, the SWA of entrained larvae could be defined relatively 

unambiguously, and there is evidence that the SWA is a source of larval production for at least 

some entrained species. Longjaw mudsucker and Pacific herring, for example, reportedly spawn 

in Elkhorn Slough (Duke Energy, 2000). There are also studies indicating that other target 

species (e.g., gobies) are marsh residents (e.g., Yoklavich et al., 1991). 

Table 4. Summary of analysis of HPF assumptions for the MLPP, MBPP, DCPP, and 

HBGS. See text for details.

Power 

plant 

SWA used 

to estimate 

HPF 

Replacement 

habitat 

Larval 

production is 

habitat-limited

Replacement 

habitat includes 

source of larval 

production

Aerial 

extent of 

SWA can be 

reliably 

determined

Habitat of 

SWA is 

uniform and 

larvae 

are evenly 

distributed 

Moss 

Landing 

Elkhorn 

Slough, 

which 

contains 

open water, 

marsh 

mudflats, 

tidal creeks 

Same No evidence 

provided, but 

likely for 

resident species 

and assumption 

is consistent 

with efforts to 

restore Elkhorn 

Slough 

Evidence for 

longjaw 

mudsucker, 

Pacific herring 

Yes No. SWA 

contains diverse 

habitats, and 

larval densities 

are likely to be 

greater in marsh, 

mudflats, and 

tidal creeks than 

in open water. 

Morro 

Bay 

Open water 

of bay 

No 

replacement 

habitat 

proposed; HPF 

estimates used 

to develop cost 

estimates for 

sediment 

reduction 

program 

No evidence 

provided, but 

likely for bay 

species because 

of habitat 

degradation in 

the estuary 

No evidence 

provided, but 

nearshore habitats 

of bay are likely 

areas of larval 

production for 

bay species 

Yes, for the 

bay SWA 

No. SWA 

contains diverse 

habitats, and 

larval densities 

are likely to be 

greater in marsh, 

mudflats, and 

tidal creeks than 

in open water. 

 
18

Table 4. Summary of analysis of HPF assumptions for the MLPP, MBPP, DCPP, and 

HBGS. See text for details (cont.).

Power 

plant 

SWA used 

to estimate 

HPF 

Replacement 

habitat 

Larval 

production is 

habitat-limited

Replacement 

habitat includes 

source of larval 

production

Aerial 

extent of 

SWA can be 

reliably 

determined

Habitat of 

SWA is 

uniform and 

larvae 

are evenly 

distributed 

Diablo 

Canyon 

Open coast Rocky reef No evidence 

provided, but 

unlikely for 

open coast 

species 

Unknown and 

difficult to 

determine 

No No information 

provided, but 

likely in coastal 

waters. 

Huntington 

Beach 

Soft-bottom 

habitat 

Wetlands No evidence 

provided, but 

unlikely for 

open coast 

species 

Unknown and 

difficult to 

determine 

No No information 

provided, but 

likely in coastal 

waters. 

However, because the replacement habitat is within the affected area, it may not increase larval 

production, particularly to the level needed to offset losses (i.e., as more larvae are produced in 

Elkhorn Slough, more larvae may be entrained). 

Two major shortcomings of the MLPP HPF are common to all HPF analyses. First, the HPF 

considers only one year of loss and one year of potential gain in the replacement habitat, and 

therefore does not account of ongoing power plants losses nor the trajectory of potential 

restoration gains. In addition, the HPF assumes that the density of larvae in the water column, 

estimated from ETM modeling, is equivalent to larval productivity and can be taken as an 

estimate of the increase in larval production needed to offset entrainment. As discussed 

previously, for this assumption to be valid it must be shown that (1) those individuals observed at 

the time of abundance sampling are all the individuals of the age sampled that will be produced 

that year, (2) there is no turnover, and (3) there is no immigration or emigration. 

3.4.2 Morro Bay Power Plant 

The Morro Bay Power Plant (MBPP) is located on the northeastern shore of Morro Bay near the 

city of Morro Bay in central California. The intake of the MBPP entrains both bay and nearshore 

coastal taxa, and therefore it was necessary to divide the SWA into two sub-areas for purposes of 

ETM modeling, bay water and nearshore coastal water. Calculation of the SWA was also 

complicated by the fact that the intake is subject to daily tidal flows. The large tidal exchange in 

the bay results in rapid turnover of bay waters. The volume of the Morro Bay component of the 

SWA was estimated as the sum of the bay’s nontidal volume and the twice daily tidal exchange 

of the bay’s average tidal prism, adjusted for tidal exchange. The area outside of Morro Bay in 

Estero Bay was treated as a static volume equal to the volume of Morro Bay uncorrected for tidal 
19

exchange. The size of the SWA beyond these sampled areas was estimated using current data. 

(Steinbeck et al., 2007). 

An HPF analysis for the MBPP was based only on bay species and the bay SWA. As shown in 

Table 4, the PM was estimated as 33% and the SWA was estimated as 2,300 acres, resulting in 

an estimated replacement habitat of 759 acres (33% × 2,300; CCRWQCB, 2004). This analysis 

assumes, like other HPF analyses, that standing stock can be used as a proxy for rates of larval 

production in the replacement habitat, and also fails to consider power plant losses and 

restoration gains over time. The facility presented a proposal for a Habitat Enhancement Program 

(HEP) that had similar flaws, including the failure to show the nexus between the loss of larvae 

from entrainment and the gain in larval production as a result of restoration (Duke Energy, 

2002).3

 In addition, the HPF analysis incorrectly used the cost to purchase and/or restore the 

estimated amount of replacement habitat as a proxy for the value of entrainment losses (see 

Section 3.8 for discussion of appropriate use of habitat replacement costs). Based on these costs, 

the Regional Board concluded that the total value of the entrainment losses is $8.5 million (based 

on the facility’s assumption of a 10% larval loss) or $28 million (based on the staff’s assumption 

of a 33% larval loss; CCRWQCB, 2004). 

3.4.3 Diablo Canyon Power Plant 

The Diablo Canyon Power Plant (DCPP) is a nuclear-fueled generating facility located on the 

open coast in central California, between the cities of Morro Bay and Avila Beach. Local 

biologists determined that almost all of the fish species lost to entrainment at DCPP are 

associated with shallow rocky reefs. Therefore, the HPF analysis for DCPP focused on 

estimating the amount of rocky reef habitat that would be needed to offset entrainment losses of 

rocky reef fishes (Raimondi et al., 2005). 

The amount of rocky reef restoration needed to offset entrainment losses was estimated by 

multiplying the PMAVG for the rocky reef fishes entrained (10.76%) by the estimated area of 

rocky reef within the SWAAVG of the nine species. Two alongshore areas were selected as 

potential locations of the SWA, one centered at the DCPP and the other with a southern limit 

near the DCPP. Within each location, the SWA was assumed to be an area 74 kilometers (km) 

alongshore (the average alongshore distance traveled by the vulnerable larvae of the nine target 

species) and 3 km offshore (the offshore distance of the fish sampling grid). Two PMs were 

developed for each species based on each of these SWAs, with each SWA a function of the 

species-specific duration of the dispersing stage of the larvae and the oceanographic currents that 

transport the larvae along the coast (Raimondi et al., 2005). 

The area of rocky reef within each of these areas was determined by overlaying each of the 

potential average SWAs with a map of kelp coverage in that area, based on the assumption that 

most rocky reef along California’s Central Coast that occurs between 5 and 30 m in depth is 

likely to be covered by kelp. Because the area of offshore rocky reefs not covered by kelp is 

more difficult to estimate, the analysts applied a multiplier of 2 to this estimate to account for 

potential offshore reef area (Raimondi et al., 2005). 
20

Entrainment and HPF estimates are presented in Table 4. Applying the PMAVG (10.76%) to the 

two estimates of rocky reef area within each SWAAVG resulted in an estimate of the amount of 

artificial reef needed to compensate for DCPP entrainment of rocky reef fishes that ranged from 

200 acres to 1,000 acres (Raimondi et al., 2005). 

The HPF estimates are particularly difficult to interpret in this case. The effort to define the 

SWA for this ocean facility involved considerable effort and ingenuity, but there was still 

significant uncertainty in the resulting estimates. Improving the SWA estimates based on this 

approach would require even more extensive and costly analysis of ocean currents and larval 

dispersal, and it is unclear whether the uncertainty could be reduced sufficiently. The period of 

larval duration is particularly difficult to determine for pelagic species. 

More importantly, whether rocky reefs are a source of production or simply attract larvae 

remains a subject of debate within the scientific community (Bohnsack, 1989; Bohnsack et al., 

1994; Grossman et al., 1997). However, even if the reef restoration led to an increase in 

production, it would be necessary to manage fishing around the reef to ensure that the expected 

production was realized (Powers et al., 2003). 

3.4.4 Huntington Beach Generating Station 

The HBGS is located in Huntington Beach, in Orange County, California. Marine habitat near 

the facility is primarily sandy substrate. The Huntington Beach Wetlands, dominated by 

pickleweed (Salicornia virginica), occurs to the southeast and northwest of the facility. The 

intake of the HBGS is offshore in subtidal, sand-bottom habitat, and therefore most of species 

entrained are soft-bottom species (e.g., croakers; MBC Applied Environmental Sciences and 

Tenera Environmental, 2005). 

In May 2001, the HBGS received approval from the Energy Commission to restore and restart 

Units 3 and 4 for operation until September 2011, after the units had been retired in 1995. In 

2003, Units 3 and 4 became operational, and since that time intake flows for Units 3 and 4 have 

averaged 235.5 MGD. Total flow for all units is 507 MGD (MBC Applied Environmental 

Sciences and Tenera Environmental, 2005). 

Entrainment at the HBGS was estimated from plankton samples taken just offshore of the intake 

and based on the total intake flow of 507 MGD. Sampling identified a total of 57 taxa, but 

subsequent analyses focused on the most abundant taxa (target taxa), including three estuarine 

fish species (arrow goby, cheekspot goby, and shadow goby; collectively known as CIQ gobies), 

seven coastal fish species (white croaker, black croaker, spotfin croaker, queenfish, blennies, 

diamond turbot, and California halibut), and rock crab megalops. Source water populations of 

larvae were estimated from samples collected at the station and six other stations extending 4 km 

upcoast, downcoast, and offshore of the intake structure (Davis et al., 2006b). 

Because the refurbishing of Units 3 and 4 is considered a new source of entrainment, the impact 

analysis was for entrainment at these two units only. Intake flow and entrainment for Units 3 and 

4 is about half of total at HBGS (Davis et al., 2006b). 
21

Two estimates of the SWA were developed using two different alongshore lengths: one based 

only on alongshore current movement (12.8 km) and the other based on both alongshore current 

and an extrapolation of larval densities offshore to a distance bounded by either the extrapolated 

densities or the onshore current (84.9 km). The width of the SWA was based on the area of 

plankton sampling (5 km). On this basis, the two estimates of the SWA were 0.11 km2

 and 

4.47 km2

, or an average of 1.50 km2 (MBC Applied Environmental Sciences and Tenera 

Environmental, 2005). 

Entrainment and HPF estimates are presented in Table 4 for target species found in soft-bottom 

habitat. Because there is no practical method to create soft-bottom habitat, the restoration 

proposal focused on out-of-kind restoration, specifically wetland restoration.4

 The HPF estimate, 

based on the PMAVG and SWAAVG for the target species, was 104 acres based on entrainment at 

Units 3 and 4 (Davis et al., 2006b). Two target taxa, gobies and northern anchovies, were not 

included in this HPF analysis, because gobies do not occur near HBGS as adults, and northern 

anchovies occur over a much larger area than the nearshore SWA (Davis et al., 2006b). 

An alternative HPF estimate by facility consultants used goby for scaling because most of the 

entrainment is of goby, which are produced in wetlands, specifically in mudflat habitat. The HPF 

estimate for the CIQ goby complex was 15.35 acres (Davis et al., 2006b). 

The total cost to restore 104 wetland acres was based on estimates of $74,660 per acre for initial 

restoration costs and $784 per acre for operation and maintenance, for a total of $75,444. Cost 

estimates were developed by restoration experts working on the Huntington Beach Wetlands 

(Davis et al., 2006b). Assuming a maintenance period of 10 years (the term of the HBGS 

license), the cost to restore the 104 acres was estimated as $7,956,000 (Davis et al., 2006b). 

Like the HPF for the DCPP, a significant limitation of the HPF analysis for the HBGS is the 

difficulty in defining the SWA. As the HBGS entrainment study noted, the larval dispersal 

distance used to define the SWA for larvae entrained by coastal intakes has a significant 

influence on ETM estimates of entrainment and the PM (MBC Applied Environmental Sciences 

and Tenera Environmental, 2005). 

3.4.5 Summary of omissions, biases, and uncertainties in HPF analyses 

Table 5 provides a summary of how particular HPF assumptions may affect estimates of the 

appropriate scale of needed restoration. The potential implications are uncertain for some 

assumptions. For example, the common inability to reliably convert entrainment losses into a 

proportion of the SWA, could either under- or over-estimate actual rates of larval production. On 

the other hand, the directions of some other biases are clear. For instance, the lack of discounting 

will result in a potentially significant underestimate of the scale of future restoration required to 

offset past and continuing losses. 

Taken together, the biases of the HPF have the potential to significantly underestimate the scale 

of restoration required to offset entrainment losses. 
22

Table 5. Summary of omissions, biases, and uncertainties in HPF scaling

Issue Comment 

Effect on estimated 

scale of restoration 

HPF assumes that ETM sampling of 

open waters of SWA samples larval 

habitats 

Nearshore habitats such as marshes, tidal 

creeks, mudflats, and submerged aquatic 

vegetation (SAV) are not sampled. 

Potentially large in either 

direction 

HPF must assign a SWA, even 

when hydrodynamics, habitat 

diversity, and entrainment life 

histories are too complicated to be 

modeled reliably 

Few intakes are located where simplifying 

assumptions will be valid; a highly variable 

PM over time may indicate issues. 

Potentially large in either 

direction 

HPF assumes the density of 

organisms in SWA at the time of 

sampling is equal to the rate of 

larval production 

Measures of standing stock can only be used 

as a proxy for rates of production under very 

limited circumstances (i.e., when all the 

organisms recruited to the population that 

year are sampled and there is no immigration 

or emigration between the time of larval 

production and the time of sampling). 

Underestimate 

HPF averages PM and SWA for 

multiple species 

Average PM and average SWA are not 

meaningful. Restoration requirements depend 

on each species’ habitat requirements. Scaling 

should be based on the species requiring the 

maximum. 

Underestimate 

HPF evaluates habitat losses and 

gains without accounting for time, 

including discounting 

Losses and gains occur over time, not in a 

single instant. 

Underestimate 

HPF assumes SWA habitats 

produce larvae 

Local habitats may not be the source of local 

larvae. 

Unknown 

HPF assumes SWA and 

replacement habitat are equivalent 

in quality 

Restored habitat rarely functions as well as 

existing habitat. However, restoration sites 

may occasionally be available that are better 

than habitats that happen to be in the SWA. 

Usually underestimate 

HPF assumes larval habitat is 

limiting for local fish populations 

The factors that limit affected populations 

must be demonstrated. 

Underestimate if 

assumption is not met 

3.5 HPF Alternatives 

3.5.1 Alternative scaling approach 

A straightforward alternative to the HPF approach would compare directly the measure of larval 

entrainment with gains in larvae from habitat restoration. An example of this type of approach is 

the habitat-based replacement cost (HRC) method described in Strange et al. (2004b) and Allen 

et al. (2005b).5

 An HRC analysis quantifies the amount of habitat needed to produce organisms 

equivalent to those lost to entrainment (i.e., the same species and life stages). In this sense, it is a 

hybrid of the REA and HEA scaling approaches often used in NRDA cases (NOAA, 1997).

Box 1 compares restoration estimates using the HPF method with the HRC approach. 
23

Unlike the HPF, this type of approach does not require larval sampling of the water body to 

determine the size of the larval population of each species and the portion of each larval 

population at risk of entrainment. Therefore, it does not require modeling of the complexities of 

SWA-wide hydrodynamics and SWA-wide larval dispersal, nor does it depend on the special 

circumstance of relatively uniform habitat in an easily defined SWA for which larval dispersal 

distances can be reliably estimated. The main difficulty with the HRC and similar methods is 

estimating rates of fish production. The following section describes data needs and some of the 

methods available for estimating production rates. 

3.5.2 Developing estimates of fish production 

To estimate fish production for habitat scaling purposes, one could (1) rely on site-specific data 

(such as the larval data collected for parameter ρ of the ETM), or (2) rely on published 

information. Some of the data and methods most commonly used for developing production rates 

for scaling purposes are outlined below, followed by a table presenting examples of fish 

productivity estimates in the scientific literature. 

Box 1. Comparison of acres of restoration needed to offset entrainment of CIQ gobies 

using the HPF and HRC methods 

HBGS consultants estimated the amount of replacement wetland to offset entrainment of the CIQ goby 

complex as 15.35 acres using the HPF method.b

 Using an estimate of the rate of goby production from the 

scientific literature, it is possible to develop an alternative estimate based on the HRC approach.a

 Allen 

(1982) provides data for goby production in the littoral zone in Upper Newport Bay in southern California 

of 0.2026 grams dry weight per acre per year (g dw m-2

 yr

-1), or 820 g dw ac-1

 yr

-1. The present value 

equivalent of this annual production using a 3% discount rated is 82,820 g dw ac-1

 yr

-1. 

Using the productivity estimate from Allen (1982), the HRC method calculates the acreage to be restored 

by dividing the entrainment loss of gobies, expressed as present value dry weight loss of gobies over the 

10-year license period (338,315,003), by the present value dry weight gain of gobies per acre over the 

license period (82,820 g dw ac-1). This results in an estimate of 4,085 acres of restoration required to 

offset annual goby entrainment over the next 10 years. Though based only on goby losses, this HRC 

estimate, using the rate of production, indicates that the HPF method may substantially underestimate the 

amount of restoration required to offset power plant entrainment. 

The difference in cost using the two methods is also substantial, and determining the best estimate could 

be particularly important in settlement negotiations, even in cases where restoration is not actually 

implemented (e.g., for the Salem facility in Delaware Bay). Based on the cost used for HPF estimates of 

$75,444 per acre,b

 and the HRC estimate of the scale of restoration for CIQ gobies (4,085 acres), the cost 

would be $308,182,883 – orders of magnitude higher than that based on the HPF estimate for goby of 

15.35b

 acres by HBGS’s consultant ($75,444 × 15.35 = $1,158,065) or the HPF estimate for all species of 

104b

 acres by Energy Commission consultants ($75,444 × 104 = $7,846,176). 

a. Strange et al. (2004b); Allen et al. (2005b). 

b. Cited in Davis et al. (2006b). 

c. Discounting converts losses and gains to “present value equivalents” to account for time lags and to 

express results in terms of a common year (NOAA, 1997, 1999; U.S. EPA, 2000). NOAA and other 

resource agencies generally use a 3% discount rate (NOAA, 1997, 1999). 
24

Techniques for calculating rates of production are discussed at length in a report for the Energy 

Commission entitled Research on Estimating the Environmental Benefits of Restoration to 

Mitigate or Avoid Environmental Impacts Caused by California Power Plant Cooling Water 

Intake Structures (Strange et al., 2004a). A special issue of the journal Marine Ecology Progress 

Series (Volume 264, 2003) provides several examples of quantitative methods for scaling 

restoration, including demographic and growth models for single species and trophic transfer 

modeling to scale restoration across multiple trophic levels. Methods for estimating fish 

produced by habitats are summarized below. 

Annual rate of fish production 

Fish productivity is a measure that integrates the recruitment, growth and survival of the 

individuals in a cohort or population. It is a comprehensive measure of the ecological benefits of 

habitat restoration. Productivity estimates for each species allows determination of which species 

requires the largest amount of restoration, which ensures that there will be sufficient restoration 

for all species. 

A number of methods are available for estimating rates of fish production from field sampling. 

Cohort-based methods include (1) removal summation, (2) increment summation, (3) the 

instantaneous growth rate method, and (4) Allen’s graphical method (Waters, 1977; Newman 

and Martin, 1983; Wootton, 1990). The removal summation method is based on the concept that 

production by a cohort eventually dies or is otherwise removed. The method involves assessing 

the reduction in numbers in a cohort throughout its lifetime (Waters, 1977). 

The increment summation procedure involves taking samples of individual weights periodically 

throughout the life of the cohort. From one sample to the next, the growth increment is estimated 

as the increase in mean individual weight. This estimate is multiplied by cohort numbers during 

the interval to estimate production during the period. The sum of all such estimates gives an 

estimate of production by the entire cohort (Waters, 1977; Newman and Martin, 1983; Morin 

et al., 1987). 

The instantaneous growth rate method (Ricker, 1975) assumes that the instantaneous rate of 

growth per unit weight, g, and the instantaneous mortality rate, Z, are constant over the time 

interval for which production is to be estimated (Chapman, 1978; Wootton, 1990). In this case: 

P = gB0 (eg-Z – 1) / g – Z (Equation 5) 

where: 

B0 is the biomass of the individuals in a cohort at the start of the interval. On this basis, 

production can be calculated from one observation of biomass. 

An extension of the Ricker (1975) instantaneous growth rate method is the graphical method of 

Allen (1971). This method estimates production using a curve in which mean individual weight, 

w, is plotted against cohort size, N, at particular times and then assessing the area beneath the 

curve (Chapman, 1978; Wootton, 1990). 
25

A cohort-free size-frequency approach for estimating secondary productivity (Hynes, 1961; 

Hynes and Coleman, 1968) is conceptually similar to removal summation, but it involves 

summation of losses between successive size groups instead of successive times (Hamilton, 

1969; Waters, 1977; Menzie, 1980; Cicchetti, 1998). 

Production foregone 

Production foregone considers the biomass that would have been produced by the organisms lost 

had they lived their remaining lifetime (Rago, 1984; Dixon, 1999). Restoration scaling based on 

production foregone has included the lost production of affected individuals only (e.g., French 

McCay et al., 2003) or alternatively, their lost production plus the production of progeny that 

were not produced because of the deaths of the affected individuals (e.g., Sperduto et al., 2003). 

Production:biomass ratio 

A production:biomass (P:B) ratio is an index of the rate of production of the individuals within 

an area per unit of biomass (Randall and Minns, 2000). A P:B ratio based on a one-year time 

frame is the ratio of annual production of those individuals to their mean annual biomass. 

Multiplication of the P:B ratio by mean biomass provides a measure of production when only 

biomass is known. Based on a review of fish production studies and P:B ratios for tidal marshes, 

Kneib (2003) recommends a P:B ratio of 2 for marsh fishes. Kneib (2003) notes, however, that 

ratios may be considerably higher for early life stages (e.g., 7.55 for young-of-year fish reported 

by Allen, 1982). 

Use of abundance as a proxy for production 

If the P:B ratio is 1, then abundance estimates can be used as a proxy for annual production if 

(1) those individuals observed at the time of abundance sampling are all the individuals of the 

age sampled that will be produced that year, (2) there is no turnover, and (3) there is no 

immigration or emigration. Abundance may be less than production if there is immigration, 

multiple spawning bouts not covered by the sampling regime, or sampling inefficiency 

(including gear inefficiency or failure to adequately sample a patchy habitat). Abundance may be 

greater than production if there is emigration. These factors must be taken into account in 

determining if it is appropriate to assume that an estimate of standing stock is a reasonable 

surrogate for direct estimates of fish productivity. 

Abundance estimates from fish surveys in the habitat types to be restored are sometimes used to 

estimate rates of production. Typically, survey data are reported as catch per unit effort (CPUE), 

the number or weight of fish taken by a defined unit of sampling effort (e.g., number of fish 

caught per trawl). 

To estimate rates of production for the purpose of scaling restoration, it is necessary to use 

CPUE data for the relevant habitat and to convert the data to an equivalent estimate of abundance 

per unit area, defined by the area sampled. In most cases, CPUE data must also be adjusted to 

account for the sampling efficiency of the gear used, especially for early life stages. Often, 

CPUE data are available from peer-reviewed studies for specific habitat types (e.g., SAV, tidal 
26

wetlands). However, broad-based sampling programs (e.g., those conducted by state or federal 

agencies) may record catch information with a site identification number without any habitat 

description. In such cases, discussions with individuals familiar with the sampling locations, and 

review of supporting documentation (e.g., annual program summaries), will enable definition of 

the habitat categories for sampled locations. 

Estimates of sampling efficiency may occasionally be incorporated in sampling reports, but 

information is also available for some types of gear in the published literature (e.g., Rozas, 1992; 

Jordan et al., 1997; Rozas and Minello, 1997; Bayley and Herendeen, 2000). If there are no other 

sources of data, those conducting the sampling can be contacted for their professional estimate of 

the gear efficiency based on the conditions encountered or informal and unreported assessments 

(e.g., use of underwater cameras to record field performance of trawls). 

Trophic transfer modeling 

There is increasing interest in estimating the production of communities rather than populations 

of single species. Trophic modeling of energy transfer through the local food web is one 

approach that has been used for the purposes of restoration scaling. Trophic transfer models are 

based on the connection between salt marsh primary production and the secondary production of 

both resident and transient fish and shellfish (Kneib, 2003). 

Kneib (2003) developed a simple trophic transfer model to estimate the annual production of 

nekton resulting from the annual production of Spartina marsh. The model is outlined in 

Figure 2.6

 

This type of approach was applied to estimate the marsh area needed to offset impingement and 

entrainment at the Salem facility in Delaware Bay (PSE&G, 1999; Teal and Weinstein, 2002). 

The model estimated the amount of fish produced by a given amount of marsh primary 

production based on published studies of marsh food webs in local areas (e.g., a New Jersey 

study by Rountree and Able, 1992). See Box 2 for details on this analysis. 

Fish production estimates in the scientific literature 

There are a number of published studies of fish production rates that have been used for 

restoration scaling, and a sample of these is provided in Table 6. In the absence of site-specific 

and species-specific data, literature values can provide a reasonable first-order approximation for 

scaling restoration. Once restoration activities begin, restoration monitoring can be designed to 

obtain the data needed to develop estimates for local species and site conditions and the 

restoration can then be adapted as needed to ensure a more accurate match between entrainment 

losses and gains from restoration. 
27

Nekton = 0.2 + 4.0 = 4.2 g dw m-2

Fungi

900 x 0.55 = 495

Bacteria

495 x 0.67 x 0.1 = 33 g

Spartina 1,000 g Benthic algae 250 g

Herbivores

1,000 x 0.1 x 0.1 x 0.2 = 2 g

Benthic/epibenthic consumers

25 + 3.3 + 16.3 = 44.6 g

Residents 2.8 g Migrants 1.4 g

Above-ground net primary production 1,250 g dw m-2

Figure 2. Production flows to nekton from net annual marsh primary production. Based 

on Kneib (2003). 

Box 2. Example of power plant restoration scaling using a trophic modeling approach 

A member of one of the agencies involved in the scaling analysis for the Salem facility in Delaware Bay 

summarized the trophic modeling process as followsa

: 

Step 1: Determine total annual marsh primary production by adding estimates of primary production by 

marsh plants and by benthic algae: 

72,790 lbs/ac/yr (plants) + 7,145 lbs/ac/yr (benthic algae) = 79,935 lbs primary production/ac/yr. 

Step 2: Assuming that about 45% of this annual primary production is transported out of Delaware Bay, 

primary production within the bay is given as: 

79,935/lbs/ac/yr × 0.55 = 43,964 lbs primary production/ac/yr. 

Step 3: Most biomass of marsh plants passes through a detrital food web. Assuming that 40% of plant 

primary production is converted to organic detritus, then: 

43,964 lbs/ac/yr × 0.40 = 17,586 lbs/ac/yr detritus. 

Step 4: Allocate the detritus among invertebrates (33%) and fish (67%). Then, on this basis, the amount of 

detritus consumed by fish is: 

17,586 lbs/ac/yr × 0.67 = 11,782 lbs/ac/yr detritus. 
28

Box 2. Example of power plant restoration scaling using a trophic modeling approach

(cont.) 

Step 5: Assume that this organic matter is converted to fish biomass as follows: 

Organic matter → primary consumers (arthropods) → secondary consumers (age 1 fish). 

Assuming a 20% conversion efficiency among trophic levels,b

 then the fish biomass produced is given as: 

11,782 lbs/ac/yr × 0.2 × 0.2 = 471 lbs/ac/yr of fish biomass produced. 

Step 6: Partition this biomass among the fish species impinged and entrained based on species-specific 

mortality rates for age 1 fish: 

Species 

Percent of total age 1 impingement 

and entrainment mortality 

(col a) 

Total fish biomass

(lbs/ac/yr) 

(col b) 

Species specific production

(lbs/ac/yr) 

(col a × col b) 

Bay anchovy 36.4% 471 171 

Weakfish 6.1% 471 29 

Spot 9.6% 471 45 

White perch 10.7% 471 50 

Other fish 37.2% 471 175 

Totals 100% NA 471 

Step 7: Determine the area of salt marsh (acres) needed to offset each species losses by dividing the 

biomass of each species lost per year (lbs/yr) by the biomass of that species produced per acre of salt marsh 

per year (lbs/ac/yr): 

Bay anchovy: 1,280,304 lbs/yr / 171 lbs/ac/yr = 7,487 ac 

Weakfish: 127,463 lbs/yr / 29 lbs/ac/yr = 4,395 ac 

Spot: 252,869 lbs/yr / 45 lbs/ac/yr = 5,619 ac 

White perch: 62,350 lbs/yr / 50 lbs/ac/yr = 1,247 ac 

Step 8: Use the acreage for the species requiring the maximum as the total area to be restored, which in this 

example is 7,487 acres. 

The resulting estimate of the amount of replacement habitat needed to offset entrainment losses was not 

used directly to determine the scale of restoration, but it did form the basis for settlement negotiations that 

ultimately determined what restoration would be implemented, taking into consideration cost and the 

availability of suitable restoration sites. 

a. Information provided in a October 16, 2003 memorandum to Liz Strange and Dave Mills of Stratus 

Consulting by Bruce Freeman of the New Jersey Division of Fish and Wildlife, Trenton, New Jersey 

(Freeman, 2003). Information is also in the Salem 1999 permit application (PSE&G, 1999). 

b. Conversion efficiency refers to the production of predator per unit of production of prey (i.e., production 

transferred from one trophic level to the other). 
29

Table 6. Estimates from the published literature of rates of secondary production in 

coastal habitats (in grams dry weight per square meter per year, g dw m-2 yr-1) 

g dw m-2 yr

-1 Location Source 

9.4 Estuary, Upper Newport Bay, CA Allen (1982) 

8.6 Coastal Lagoon, Mexico Warburton (1979) as cited by Allen et al. (2006) 

8.4 Restored Salt Marsh, NJ Teo and Able (2003) 

1.6 Great Sippewissett Marsh, MA Valiela et al. (1977)a 

7.4-8.0 Marsh, Goodwin Islands, VA Cicchetti (1998)b 

8.1 Marsh Creek, DE Meredith and Lotrich (1979)c 

4.2-4.6 Marsh Creek, VA Weinstein and Walters (1981), Weinstein (1983) 

0.3-7.5 Marsh Creek, NC Currin et al. (1984) 

Sources: based on Table 5-9 in Allen et al. (2006) and Table 5 in Strange et al. (2002). 

a. Corrected for arithmetic errors in original. 

b. Estimate is for nekton (fish and shrimp) for 150 days, corrected for poorly sampled smaller size classes. 

c. Wet weights converted to dry weights using a conversion factor of 0.25. 

Data sources for scaling metrics and data gaps 

Data needed for these scaling metrics include size-frequency data, length and weight 

measurements for a sample of individuals, and repeated sampling events. ETM studies provide 

much of this information, including data for multiple sampling events (e.g., Tenera, 2000a, 

2000b, 2001; MBC Applied Environmental Sciences and Tenera Environmental, 2005): 

` Abundance of larvae by size class 

` Lengths and weights of larvae 

` Average age of larvae (estimated using otolith techniques or from average length by 

dividing the difference between the average and minimum lengths by a daily larval 

growth rate from the scientific literature). 

3.5.3 Restoration monitoring and adaptive management 

Even using the best methods and data available for estimating annual production rates, 

uncertainties will remain that can be addressed with ongoing monitoring and adaptive 

management of restoration actions (Hilborn, 1987; Julius, 1999). In general, there is a lack of 

data to estimate potential year-to-year variability in fish abundances and production rates. There 

is also little information on how production rates may differ in restored compared to unaltered 

habitats, or how rates may vary over the time horizon of a particular restoration action. 

Restoration monitoring focused on collecting the data needed to estimate annual rates of 

production will help fill critical data gaps for measuring the success of fish restoration actions. 
30

3.5.4 Guidelines for restoration scaling 

Guidelines for developing more scientifically rigorous and reliable restoration scaling include the 

following: 

` Base scaling on fish productivity not standing stock 

` If such information is not available in the scientific literature or existing larval sampling 

data, develop a first-order approximation of the scale restoration using a method such as a 

P:B ratio (Kneib, 2003) or trophic modeling (e.g., PSE&G, 1999), and then conduct field 

studies of the replacement habitat to measure actual rates of growth and survival of the 

species and life stages of concern 

` Based on monitoring results, conduct adaptive management of restoration actions to 

rescale restoration as needed. 

3.5.5 Recommended elements of a restoration proposal 

Restoration proposals should include the following: 

` Definition of restoration goals, including identification of the nexus between loss and 

gain (e.g., losses of larvae from entrainment and gains in habitat needed to produce 

equivalent larvae) 

` Estimates of anticipated restoration gains and the basis for estimates (e.g., estimated fish 

production per acre per year) 

` Estimated time before ecological benefits will accrue 

` Anticipated duration of ecological benefits 

` Performance standards (success criteria) for accomplishing restoration goals and 

monitoring to ensure performance standards are being met (e.g., actual fish production 

per acre per year from field sampling) 

` Adaptive management process to improve performance as needed 

` Clearly substantiated cost estimates. 

3.5.6 Scaling alternatives when species are not habitat-limited 

When habitat restoration does not offset entrained fish (e.g., for species that are not habitatlimited), restoration can be still scaled based on value equivalence to determine other appropriate 

trade-offs. For example, VEA can be used to identify restoration alternatives of equal value to 

the public, regardless of their effect on fish production (Allen et al., 2005a; Lazo et al., 2005). 
31

3.6 Use of Restoration Costs in Cost-Effectiveness and CostBenefit Analyses 

3.6.1 Cost-effectiveness analysis 

Understanding the cost to the permit applicant of implementing technology to reduce 

impingement and entrainment versus the cost to the public to mitigate losses absent the 

technology is directly relevant to agency decisions about the cost-effectiveness of various 

technologies that could be required in an NPDES permit. That is, the cost to the public of enough 

habitat restoration to offset entrainment (without an entrainment-reducing technology) may be of 

a similar magnitude as the cost to the permit applicant to install an entrainment-reducing 

technology. If so, then there is considerable agency justification to require the technology, 

additional to the statutory requirement to install BTA. EPA has successfully argued this point as 

part of its justifications for 316(b) technology requirements in the recent Brayton Point, 

Massachusetts NPDES permit. 

Fish replacement costs have also been used at other sites to estimate the cost to the public of 

offsetting impingement and entrainment. However, most estimates of fish replacement costs 

have been based on the costs of raising and stocking hatchery fish (AFS, 1993; Southwick and 

Loftus, 2003). The cost of habitat restoration sufficient to offset entrainment provides an 

ecologically-based alternative to estimating replacement costs (Strange et al., 2004b). Although 

fish stocking has the advantage of quickly restoring fish that are targets of commercial and 

recreational fishing, hatchery fish are not ecologically equivalent to wild fish and therefore may 

fail to fully recover all lost services (Meffe, 1992; NRC, 1996; White et al., 1997). As the 

American Fisheries Society (AFS) notes, “Hatchery-raised fish may not be of the same quality in 

terms of survivability, genetic make-up, or ecological services provided compared to wild fish” 

(Southwick and Loftus, 2003). As a result, stocking is often rejected as a restoration option in 

NRDA cases involving fish kills (Reinharz and Burlington, 1996). 

The HRC method estimates the cost of restoring habitat to the level necessary to offset fish 

losses through natural production. Natural production ensures that the resulting fish offset fully 

both ecological and human use services lost because of entrained fish. It is also consistent with 

the current emphasis on the habitat needed to support self-sustaining fish populations over the 

long term (NRC, 1996; Myers et al., 2004). 

3.6.2 Cost-benefit analyses 

For expensive technologies that may be required in a NPDES permit, applicants and agencies 

often perform cost-benefit analyses, primarily to ensure that the cost of BTA is not “wholly 

disproportionate”7

 to its benefits. Although habitat restoration costs are highly relevant to agency 

decisions about technology requirements in NPDES permits, restoration costs are not necessarily 

equivalent to the value of benefits resulting from the restoration. The cost of a natural resource is 

the sum total of the underlying elements required to produce or obtain the resource. The value of 

a natural resource is the maximum amount one is willing to offer in a voluntary exchange for the 
32

resource, where value can be expressed in either ecological or monetary terms (Freeman, 1993; 

Kopp and Smith, 1993). 

Under some circumstances, restoration costs can indicate the value of restoration. For instance, 

voluntary funding for restoration in the region of the facility could be evidence of economic 

demand for those restoration actions. EPA’s Guidelines for Preparing Economic Analyses state 

that the use of replacement cost as a proxy for value may be justified “...when individuals are 

proven willing to incur such replacement costs, through either their voluntary purchases or their 

support for public works projects. If so, the value of the service is at least as much as the 

replacement cost” (U.S. EPA, 2000, p. 99). However, even where voluntary restoration has 

occurred, assumptions about value may require evidence that restoration decisions were not 

based on economically inefficient influences, such as agency mandates. 

Because restoration costs cannot simply be assumed to equal the value of benefits, additional 

economic analysis may be needed to determine the relationship between restoration costs and 

restoration benefits. Unfortunately, analyses by permit applicants have been based on an 

incomplete accounting of benefits compared to a complete accounting of costs. The potential 

values of forage fish, the vast majority of entrainment losses, are often omitted altogether. 

Sometimes the indirect use values of forage fish are estimated using simple trophic transfer 

models to account for their value as food for fishery species (e.g., Bingham et al., 2005). 

However, there is considerable uncertainty associated with these simple approaches. In 

particular, results are highly dependent on the trophic transfer efficiencies that are used, which 

can vary substantial among species, locations, and time periods. 

No permit applicant, in California or elsewhere, has quantified the nonuse values of forage fish. 

Nonuse values are the values people hold for a resource that are independent of their use of the 

resource. They include so-called “existence” and “bequest” values, i.e., the values people hold 

for simply knowing a resource exists or for knowing that the resource will continue to exist for 

future generations. There are well-established survey techniques for evaluating the existence and 

magnitude of nonuse values, and there is a growing literature on the nonuse values for a variety 

of natural resources (e.g., Carson et al., 2003). 

It is sometimes argued that the nonuse values of forage fishes are unlikely to be significant 

(e.g., Bingham et al., 2005). However, this is an empirical question that should be addressed with 

research such as stated preference surveys. In fact, EPA conducted a number of focus groups to 

explore nonuse values for impinged and entrained fish and found that (1) the main motives for 

reducing impingement and entrainment were existence and bequest values (i.e., nonuse values); 

(2) both users and non-users of the affected resources held these values for reducing 

impingement and entrainment; and (3) focus group participants agreed that all fish species 

(including forage fish) play an important role in the affected ecosystems. The focus group results 

also indicated that the public requires entrainment losses expressed in terms of fish (e.g., age one 

equivalents), not larvae, in order to express values. The Focus Group Report provides additional 

detail on these and other findings (Besedin et al., 2005). 
33

4. Conclusions and Recommendations 

4.1 Conclusions 

Because of the high cost of preventative technologies and the limited options for reducing 

entrainment, permitting agencies are likely to continue to face difficult decisions about the best 

way to protect entrainable species. In cases where restoration is used to offset unavoidable 

losses, including losses that remain after implementation of BTA, it is essential to use the 

reliable data and methods to estimate the costs and benefits of restoration. Unfortunately, most 

habitat restoration projects, in this and other contexts, are undertaken with little understanding of 

the efficacy of proposed restoration, including the likely quantity of organisms that will be 

produced. 

Under some circumstances the HPF method can provide useful information relevant to scaling 

restoration for entrainment losses. For instance, an HPF can produce a reasonable estimate of the 

entrainable larvae within well defined SWAs. However, the efficacy of the HPF is limited to 

enclosed or semi-enclosed water bodies, where the extent of the SWA and larval populations can 

be reliably determined. For power plants on open coasts, where it is extremely difficult to 

determine the area over which larvae may disperse, HPF results will have significant, and 

probably unacceptable, uncertainty. Reducing this uncertainty, requires an understanding of 

complex coastal hydrodynamics, and the effort and cost do so may not be justified, particularly 

given the magnitude of uncertainties that likely would remain. 

In addition, the HPF does not reliably estimate the gain in fish production that would result from 

a given habitat restoration. In particular, the HPF equates the area within the SWA containing the 

standing stock of entrained larvae to the amount of replacement habitat needed to offset 

entrainment losses. However, restoration scaling requires an estimate of the amount of increase 

(the rate of change) in fish numbers or biomass caused by the restoration (either enhanced 

production or preservation of existing production against foreseeable loss), not an estimate of 

present standing stock. 

Furthermore, HPF estimates do not integrate fish losses and gains through time. The entrainment 

impact of a power plant is not simply the entrainment estimated for one year, but rather includes 

the accumulated losses over all years that the power plant operates. Similarly, restoration gains 

may not reach the anticipated rate of increased production for several years. Both losses and 

gains must account for these temporal considerations and be expressed in terms of present value 

equivalents. 

Appropriate restoration scaling metrics include species-specific measures of the increase in 

numbers or biomass of the species and life stages of concern in the restored habitat, quantified in 

terms of recruitment, the addition of new recruits to the population per unit area per unit time, or 

productivity, the rate of fish biomass production per unit area per unit time. These metrics are 

also the best measures of restoration success. Therefore, restoration monitoring studies are an 

important component of productivity estimates that should be required as part of any restoration 

required under the terms of an NPDES permit. 
34

Because estimates of the area to be restored and associated restoration costs may play a critical 

role in settlement negotiations, it is imperative that restoration scaling is as rigorous as practical, 

using or developing the sufficient scientific information. If the scale and costs of restoration are 

underestimated, permitting conditions may not achieve the goal of resource protection. 

Even the most robust scaling techniques currently available include uncertainties that must be 

accounted for, and any proposal for restoration to offset unavoidable entrainment losses should 

include a monitoring program to determine actual rates of fish production. The best way to 

improve restoration scaling and increase the probability of restoration success is to monitor the 

actual rates of fish production in the replacement habitat. Such monitoring will make it possible 

to manage the restoration to ensure that the quantity of fish produced will actually offset the 

entrainment loss. Monitoring will also make it possible to collect data needed to reduce scaling 

uncertainties. 

4.2 Recommendations 

` Limit use of the HPF method to estimating the amount of the SWA that is equivalent to 

the fraction of the larval population entrained 

` Estimate the HPF for power plants located on bays and estuaries only. Estimates for 

power plants located on open coasts are currently too uncertain and unreliable, even with 

extensive analysis of larval dispersal and ocean currents 

` Scale restoration based on a measure of the ecological benefits expected to result from a 

given restoration action 

` Use the same metrics for restoration scaling and monitoring 

` Conduct adaptive management of restoration activities to ensure that restoration goals are 

met 

` Design restoration monitoring to collect data that can reduce scaling uncertainty. 

` When habitat restoration does not offset entrainment losses (e.g., for species that are not 

habitat-limited), consider using value equivalency to determine appropriate restoration. 

` If fish stocking is proposed as a restoration alternative, require that the facility 

demonstrate ecological equivalence and the public’s willingness to accept a stocked 

species in place of the entrained species or in place of the production of wild fish in 

natural habitat. 
35

4.3 Benefits to California 

The information provided in this report can benefit California regulators, facility operators, 

environmental stakeholders, and the Energy Commission in several ways. Results provide: 

` Guidelines for objective, scientifically-based restoration scaling methods to address 

environmental impacts from power plants and other kinds of facilities, including 

hydropower facilities and desalination plants co-located with power plants 

` Scientifically-rigorous restoration scaling methods, combined with ongoing restoration 

monitoring that will help fill data gaps, will greatly increase the likelihood of successful 

restoration actions 

` Restoration costs based on valid restoration scaling make it possible to compare the costs 

to permit applicants of implementing technology to minimize losses with the costs to the 

public to mitigate losses absent the technology, which is directly relevant to licensing and 

permitting decisions about cost-effectiveness. 
36

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Analyses. Report Number 240-R-00-003. U.S. Environmental Protection Agency, Washington, 

DC. September. 

U.S. EPA (U.S. Environmental Protection Agency). 2004a. Technical Development Document 

for the Final Section 316(b) Phase II Existing Facilities Rule. Chapter 4: Efficacy of Cooling 

Water Intake Structure Technologies. EPA 821-R-04-007. U.S. EPA Office of Water, 

Washington, DC. Available: http://www.epa.gov/waterscience/316b/phase2/devdoc/final.htm. 

Accessed 2007. 

U.S. EPA (U.S. Environmental Protection Agency). 2004b. Response to Public Comment. 

National Pollutant Discharge Elimination System, Regulations Addressing Cooling Water Intake 

Structures (40 CFR Parts 9, 122, 123, 124, and 125). March 29. Available: 

http://www.epa.gov/waterscience/316b/phase2/comments/index.html. Accessed 2007. 

Valiela I., J.E. Wright, J.M. Teal, and S.B. Volkmann. 1977. Growth, production and energy 

transformation in the salt-marsh killifish Fundulus heteroclitus. Mar. Biol. 40:135-144. 

Warburton, K. 1979. Community structure, abundance and diversity of fish in a Mexican coastal 

lagoon system. Estuar. Coast. Mar. Sci. 7:497-519. 

Waters, T.F. 1977. Secondary production in inland waters. In Advances in Ecological Research, 

A. MacFadyen (ed.). Volume 10. Academic Press, New York, pp. 91-165. 

Weinstein, M.P. 1983. Population dynamics of an estuarine-dependent fish, the spot (Leisotomus 

xanthurus) along a tidal creek-seagrass meadow coenocline. Canadian Journal of Fisheries and 

Aquatic Sciences 40:1633-1638. 

Weinstein, M.P. and M.P. Walters. 1981. Growth, survival and production of young-of-year 

populations of Leiostomus xanthurus Lacepede residing in tidal creeks. Estuaries 4:185-197. 

White, R.J., J.R. Karr, and W. Nehlsen. 1997. Hatchery Report in the Northwest: Issues, 

Opportunities, and Recommendations. Report prepared for Oregon Trout, Portland. 

Wootton, R.J. 1990. Ecology of Teleost Fishes. Chapman & Hall, London, UK. 

Yoklavich, M.M., G. Cailliet, J.P. Barry, D.A. Ambrose, and B.S. Antrim. 1991. Temporal and 

spatial patterns of abundance and diversity of fish assemblages in Elkhorn Slough, California. 

Estuaries 14:465-480. 

York, R. and M. Foster. 2005. Issues and Environmental Impacts Associated With Once-Through 

Cooling at California’s Coastal Power Plants. California Energy Commission Staff Report, June 

2005. CEC-700-2005-013. Available: 

http://www.energy.ca.gov/siting/once_through_cooling.html. Accessed 2007. 
45

Glossary 

AFS American Fisheries Society 

BMP Best Management Practice 

BTA best technology available 

CCA California Coastal Act 

CCC California Coastal Commission 

CDFG California Department of Fish and Game 

CEIC California Environmental Information Catalog 

CEQA California Environmental Quality Act 

CERPI California Ecological Restoration Projects Inventory 

CHRPD California Habitat Restoration Project Database 

CPUE catch per unit effort 

CWA Clean Water Act 

DCPP Diablo Canyon Power Plant 

EPA U.S. Environmental Protection Agency 

ETM Empirical Transport Model 

GIS geographic information system 

HBGS Huntington Beach Generating Station 

HEA habitat equivalency analysis 

HEP Habitat Enhancement Program 

HPF habitat production foregone 

HRC habitat-based replacement cost 

km kilometer 

MBPP Morro Bay Power Plant 

MGD million gallons per day 

MLPP Moss Landing Power Plant 

MPA marine protected area 

MW megawatt 

NOAA National Oceanic and Atmospheric Administration 

NPDES National Pollutant Discharge Elimination System 

NRDA natural resource damage assessment 

NRPI Natural Resource Projects Inventory 
46

P:B production:biomass 

PIER Public Interest Energy Research 

PM proportional mortality 

RD&D Research, Development, and Demonstration 

REA resource equivalency analysis 

SAV submerged aquatic vegetation 

SCAR San Clemente Artificial Reef 

SONGS San Onofre Nuclear Power Generating Station 

SWA source water area 

VEA value equivalency analysis 

WISER Water Intake Structure Environmental Research 
47

List of Species Scientific Names 

Arrow goby (Clevelandia ios) 

Bay goby (Lepidogobius lepidus) 

Black croaker (Cheilotrema saturnum) 

Blackeye goby (Rhinogobiops nicholsii) 

Blue rockfish (Sebastes mystinus) 

Cabezon (Scorpaenichthys marmoratus) 

California halibut (Paralichthys californicus) 

Cheekspot goby (Ilypnus gilberti) 

CIQ gobies – Arrow goby (Clevelandia ios), Cheekspot goby (Ilypnus gilberti), Shadow goby 

(Quietula y-cauda) 

Clinid kelpfishes (Gibbonsia spp.) 

Combtooth blennies (Hypsoblennius spp.) 

Diamond turbot (Pleuronichthys guttulatus) 

KGB rockfishes – Kelp rockfish (Sebastes atrovirens), Gopher rockfish (Sebastes carnatus), 

Black-and-yellow rockfish (Sebastes chrysomelas) 

Longjaw mudsucker (Gillichthys mirabilis)

Monkeyface prickleback (Cebidichthys violaceus) 

Northern anchovy (Engraulis mordax) 

Northern lampfish (Stenobrachius leucopsarus)

Pacific herring (Clupea pallasii) 

Pacific staghorn sculpin (Leptocottus armatus) 

Painted greenling (Oxylebius pictus) 

Queenfish (Seriphus politus) 

Rock crab (Cancer spp.) 

Rockfishes (Sebastes spp.) 

Shadow goby (Quietula y-cauda) 

Smoothhead sculpin (Artedius lateralis) 

Snubnose sculpin (Orthonopias triacis) 

Spot (Leiostomus xanthurus) 

Spotfin croaker (Roncador stearnsii) 

Staghorn sculpin (Leptocottus armatus) 

Weakfish (Cynoscion regalis) 

White (sea) perch (Phanerodon furcatus)

White croaker (Genyonemus lineatus)
48

Attachment I. Restoration Actions and Restoration Costs 

I.2 Restoration Actions for Impinged and Entrained Species 

We developed a survey framework to solicit and evaluate the opinions of California fisheries and 

aquatic habitat restoration experts regarding the types of restoration actions that could increase 

the production of specific species. The survey was also designed to elicit the respondents’ views 

regarding the relative ability of the different actions to increase the production. 

First, this section discusses the criteria that must be met for a given restoration action to increase 

fish production. Next, we describe the survey device developed to elicit the expert opinions, and 

the motivation for the survey design. Third, we provide a brief description of the reasons each of 

the habitat restoration options were selected. Finally, we summarize the survey outreach and 

solicitation efforts and results. 

I.2.1 Conditions needed for habitat restoration to increase fish production 

For an aquatic habitat restoration project to increase fish production the restored habitat must 

satisfy at least two critical conditions. First, the habitat must play a critical role at some stage in 

the species life history as either a spawning, nursery, refuge, or forage location. Second, the 

current combination of the quality and quantity of available habitat must be a limiting factor in 

the species’ production. When these conditions are met, there is a reasonable expectation that the 

restoration action will increase the species’ production, all else equal. 

I.2.2 Survey device for eliciting expert opinion 

To evaluate whether it is reasonable to expect that implementing a habitat restoration action 

would increase production of a given species, we surveyed recognized fishery and habitat 

restoration experts in California. In addition to asking about specific habitat restoration actions, 

we also asked experts to prioritize actions in terms of their relative potential to increase 

production. To develop this information we developed an electronic survey form that allowed 

respondents to simultaneously indicate whether they believed a habitat restoration or other action 

could increase production and to rank those alternatives based on the relative size of the resulting 

production increases. 

Figure I.1 presents an example from the survey form listing the various habitat restoration and 

other specific actions experts were asked to consider. 

Box I.1 below provides a copy of the main set of instructions for completing the survey form. 
49

Alternative actions to increase production of key species entrained by cooling water treatment systems 

Rank in descending order using 1 for the action you think would provide the greatest increase in product

and largest number, for the action you think is likely to provide the smallest production incre

Leave cells blank if you don’t think the action would increase production. 

Fish 

species 

entrained in 

California 

316b 

facilities 

Latin 

name 

Restore or 

create 

submerged 

aquatic 

vegetation 

(SAV) 

habitat 

Restore 

or 

create 

giant 

kelp 

beds 

Restore 

or create 

salt 

 marsh habitat 

Restore 

or create 

estuarine 

or bay 

habitat 

Restore 

or 

create 

mud flat 

habitat 

Restore or 

create 

rocky 

intertidal 

habitat 

Restore 

or 

create 

reef 

habitat 

Reduce 

commercial 

fishing 

pressure 

Reduce 

recreational 

fishing 

pressure 

Improve 

water 

quality 

Example 

species 

3 1 

(best 

option, largest 

production 

increase) 

2 4 5 

(option expected 

to provide the 

smallest 

production 

increase) 

American shad 

Alosa sapidissima 

Arrow goby Clevelandia 

ios 

Aurora rockfish 

Sebastes aurora 

Barcheek pipefish 

Syngnathus exilis 

Figure I.1. Example from the electronic survey of fisheries and restoration experts on habitat restoration epriorities. 
50

The Example Species row in Figure I.1 indicates how information from multiple respondents 

could be summarized in terms of the following measures, among other possible options: 

` The percentage of respondents who indicated the habitat restoration would likely increase 

the species’ production 

` The distribution of responses by habitat restoration action or other option in terms of a 

percentage of all responses identifying an option expected to increase the species’ 

production 

` A summary of habitat restoration or other actions that were never identified as having the 

potential to increase a species’ production. 

Collectively, these summary results could be used to evaluate whether a consensus habitat 

restoration action could be identified for a single species or group of species. 

Box I.1. Respondent instructions for completing habitat restoration survey. 

The goal of this exercise is to record your personal opinion with respect to the types of habitat 

enhancement activities or other actions that could increase the production of the listed species and to 

prioritize those actions based on your belief as to their relative benefit. 

For those species you are familiar with we would appreciate your providing two types of information. 

First, we would like you to think about those actions that could conceivably increase the production of the 

identified species based on your knowledge of its life history including spawning and nursery habitats and 

current sources of environmental pressure (e.g., habitat loss, commercial fishing). A number of alternatives 

are provided in the columns below, along with room for additional actions that you can specify in the 

appropriate cell of the Other (1) and Other (2) columns. 

Second, we would like you to rank those actions that you think could increase production of a species by 

numbering the alternative actions. The numbering will only indicate your views of the relative merits of the 

alternatives. Number 1 will indicate the option you believe would provide the greatest increase in 

production, and the largest number will indicate the least effective action. 

In the example provided (see the Example Species row), we assume there are five actions that could 

increase the species production. Of these, salt marsh restoration is the action we assume will provide the 

greatest production increase for this species. In contrast, we assume quality improvements are likely to 

increase production, but by the smallest amount from among the available options. Options that are not 

numbered reflect a belief that their implementation will not increase species’ production. 
51

I.2.3 Review of the habitat restoration alternatives and other options presented in the 

expert survey 

We developed the list of restoration alternatives for the survey using a number of sources, 

including: 

` A review of critical habitats identified for California marine fishes (Montrose Settlements 

Restoration Program, 2005; Allen et al., 2006). 

` References to the habitat restoration as being beneficial for fish or providing important 

habitat for fish species (e.g., Montrose Settlements Restoration Program, 2005; NOAA, 

2007). 

` Information indicating the habitat restoration projects or similar actions were being 

proposed/implemented in California or other areas with a stated goal of projects being 

implemented in California or elsewhere with the goal of improving fish production or 

fish stocks in general. In the rest of this section the specific habitat restoration projects. 

` A review of the habitat restoration actions being implemented as part of the 316b permit 

agreement for the San Onofre Nuclear Power Generating Station (SONGS; Southern 

California Edison, 2007). 

` Summaries of proposed restoration projects in HPF analyses for select California power 

plants, e.g., Moss Landing (Table 3 and accompanying text by Dr. Pete Raimondi, 

University of California at Santa Cruz, in Strange et al., 2004a, based on data in Tenera, 

2000b, Morro Bay (CCRWQCB, 2004), Diablo (Raimondi et al., 2005); Huntington 

Beach (Davis et al., 2006b). 

These sources helped identify the following specific habitat restoration actions that were 

included in the expert solicitation survey (see Figure I.1): 

` Restore or create SAV habitat 

` Restore or create giant kelp beds 

` Restore or create salt marsh habitat 

` Restore or create estuarine or bay habitat 

` Restore or create mud flat habitat 

` Restore or create rocky intertidal habitat 

` Restore or create reef habitat. 

In addition to these options, the expert survey included options for reducing commercial or 

recreational fishing pressure. These options were included because, for some species, reduction 

in fishing pressures could reduce mortality of spawning females and increase larval supply. For 

example, a commercial fishing boat buyback project was developed and implemented in the 

northeast groundfish fishery in an attempt to reduce the mortality pressure from commercial 

fishing on certain groundfish stocks (Kitts and Thunberg, 1998). 
52

Improving water quality was included in the survey in an effort to gauge the perceived 

importance of water quality as a limiting factor on species production. In most situations, it will 

not be possible to link and quantify a particular water quality improvement with increased water 

quality and increased production of a specific species. However, in some circumstances (e.g., for 

small water bodies where impaired water quality is the only or primary stressor and affected 

populations can be defined) it may be possible to establish these links, at least in a qualitative 

way. 

The establishment of marine protected areas (MPAs) was identified as another possible 

alternative for increasing production of entrained species. This option is based on the goals of the 

California Marine Life Protection Act of 2002, which called for the designation and integrated 

management of a statewide network of MPAs. Among the explicit goals of the MPAs is to “help 

sustain, conserve, and protect marine life populations, including those of economic value, and 

rebuild those that are depleted” (CDFG, 2007). This goal is consistent with efforts to increase 

production of fish species. Conceptually, MPAs are intended to provide a defined refuge area 

where, within the boundaries of the MPA, fish will be free from commercial and recreational 

fishing pressure. If this relief improves spawning success and fecundity by allowing females to 

mature to later life stages, the MPAs may increase overall production. However there are a 

number of questions concerning the efficacy of MPAs, and their relatively recent adoption means 

there is currently a limited and inconclusive body of associated research to address this question. 

Finally, the Other (1) and Other (2) options in the survey were included to provide respondents 

to identify any additional actions they felt should be identified because of their potential to 

increase species production. 

I.2.4 Survey outreach and solicitation efforts 

To conduct the survey, we initially contacted individuals with expertise in California fisheries or 

experience with implementing aquatic habitat restoration projects at a number of agencies and 

institutions. The organizations these individuals represent included: 

` California Coastal Conservancy 

` California Department of Fish and Game (CDFG) 

` Moss Landing Marine Laboratories 

` NOAA 

` U.S. Fish and Wildlife Service. 

These organizations and their staff provide the opportunity to gather information from across the 

state. 

I.2.5 Results of efforts to identify and prioritize habitat restoration efforts for 

specific species 

Issues with the timing of the survey development and the extensive nature of the information 

requested have limited responses received to date despite overall interest and expressions of 

willingness to participate in the research. As a result, our current summary of matching potential 
53

habitat restoration actions to specific species relies on a summary of the literature that provides 

indications of species preferences for specific habitats or a reliance on specific habitats at certain 

life stages. The results of this summary for are presented in Figure I.2 for all species that we have 

record of having been entrained at a California cooling water intake structures based on past 

facility studies. 

The results in Figure I.2 carry a number of caveats. First, because the results are drawn from a 

literature review it was not possible to develop the relative weighting information that the 

electronic survey can capture. Further, the listing of species provides no indication of the 

frequency of their entrainment at either a specific facility or across facilities in California. 

Therefore, it is not possible to draw conclusions about the share of the overall entrainment loss at 

California Cooling Water Intake Structures that is covered by the information in this table. 

I.3 Restoration Costs 

An aquatic habitat restoration project’s cost estimate should provide a comprehensive summary 

of all of the elements that will be required to achieve the project’s stated objectives. When 

available, comprehensive cost estimates can be combined with similarly detailed cost summaries 

for completed habitat restoration projects to generate a wide range of useful cost information for 

those considering similar actions (e.g., costs per unit of habitat restored, ranges of specific unit 

costs). However, prospective users of this information face a number of challenges in 

determining whether available project cost information is truly comprehensive. 

This section has two goals. First, to clearly define the elements of a comprehensive cost estimate, 

along with an approach to help evaluate whether available project cost information is 

comprehensive. Second, the section provides a summary of restoration cost databases for 

projects that have been proposed or completed in California. Finally, we provide some 

conclusions regarding combining cost information from multiple restoration projects. 

I.3.1 Overview of a comprehensive cost estimate/summary 

A comprehensive cost estimate will include all of the anticipated costs to design, implement, and 

monitor a project. While available cost information will vary across projects, reflecting 

differences in the combination of specific activities and reporting requirements, most cost 

information is organized in terms of a combination of specific types of actions. Elements and 

activities whose costs should be included are: 

1. Habitat acquisition or access 

2. Project design, evaluation, and permitting 

3. Implementation, including labor, equipment and supplies 

4. Allowance for contingencies8

5. Operations and maintenance 

6. Monitoring 

7. Oversight and administration. 
54

Key 

A. Result developed from the information in the report AES Huntington Beach L.L.C. Generating Station Entrainment and Imping(MBC Applied Environmental Sciences and Tenera Environmental, 2005). 

E. Result developed from the information in The Ecology of Marine Fishes (Allen et al., 2006). 

P. Results initially presented in the 2004 PIER Final Project Report Research on Estimating the Environmental Benefits of RestoEnvironmental Impacts Caused by California Power Plant Cooling Water Intake Structures (Strange et al., 2004a) based on respS. Result developed from the information in the report San Diego Bay Integrated Natural Resources Management Plan (Port of 

Fish species 

frequently entrained 

at California 

power plants 

Restore 

or create 

SAV habitat 

Restore 

or 

create 

giant 

kelp 

beds 

Restore 

or 

create 

salt 

marsh 

habitat 

Restore 

or 

create 

mud flat 

habitat 

Restore or 

create 

rocky 

intertidal 

habitat 

Restore 

or 

create 

reef 

habitat 

Reduce 

commercial 

fishing 

pressurea 

Reduce 

recreational 

fishing 

pressurea 

Improve 

water 

qualitya 

Create 

Marine 

Protected 

Areas 

(MPAs)a 

Bay goby1, 6, 7 E, P P E, P E, P P P P P Blackeye goby1, 6, 7 P E, P P P P E, P P P Blennies E, P P E, P E, P A, E, P, S A, E, P, 

S 

 P 

Cheekspot goby1, 6, 7 E, P P E, P E, P P P P P Drums5, 6, 7 P P P P P Giant kelpfish2, 6 S E, S E, S Northern anchovy A, E A, E A, E P P P Queenfish2 

A (open 

S (d

Rockfish (Blue, Gopher, Grass, Kelp)6, 7 

 E, P E, P E, P P P P 

Smoothhead sculpin3, 6, 7 E E P Spotted kelpfish2, 6 E E S (uStriped kelpfish2, 6, 7 E E Action Notes a. These actions were not assessed for their relationship to specific species in The Ecology of Marine Fishes, the AES Huntingto

Diego Bay Integrated Natural Resources Management Plan. 

Species Notes 1. Results from the 2004 PIER report reflect responses for “Gobies” and were not distinguished by species. 

2. Species not addressed in the 2004 PIER report. 3. Results from the 2004 PIER report reflect responses for “Sculpins” and were not distinguished by species. 4. Results from the 2004 PIER report reflect responses for “Drums croakers” and were not distinguished by species. 5. Species not addressed in The Ecology of Marine Fishes. 6. Species not addressed in The AES Huntington Beach report. 7. Species not addressed in the San Diego Bay Integrated Natural Resources Management Plan. 

Figure I.2. Indications of habitat requirements and potentially beneficial habitat restoration actions for se

available literature. 
55

Collectively, the above list of cost categories accounts for all phases of a restoration project from 

the design phase through actual implementation and long-term maintenance and monitoring to 

ensure project performance. Each of these cost categories is discussed below. 

` Habitat acquisition or access: At a minimum, a restoration project proponent needs to 

demonstrate legal control or approved access to a site to undertake habitat restoration 

activities. Acquiring direct ownership of the habitat (e.g., through a fee-simple purchase) 

is the most direct and certain expression of this control. Other options for achieving this 

control can include obtaining a conservation easement, lease arrangements, or unsecured 

access guarantees with a willing project sponsor with access to the habitat. The costs for 

obtaining the habitat and securing access are, for many categories of habitat restoration 

projects, likely to represent a significant portion of total expenses and the associated cost 

needs to be clearly identified in a cost estimate/summary. 

` Design and permitting: Most habitat restoration projects will require some sort of permit 

or regulatory review process prior to implementation (e.g., CEQA review). Both the 

project and the permitting process are also likely to require construction, engineering, and 

or detailed implementation sequencing plans. Depending on the location, type, and 

complexity of the project, these costs can be significant. If detailed estimates cannot be 

developed, these costs can still be accounted for with either a lump sum estimate or an 

estimate based on a percentage of other identified costs (e.g., 20% of anticipated 

construction costs). 

` Implementation: This cost element should summarize all costs associated with labor, 

equipment, and materials required for the project. These costs should also incorporate any 

expenses associated with mobilization and demobilization required to bring equipment 

and material to a project site or to provide actual site access during the active restoration 

phase of the project. 

` Allowance for contingencies: An allowance for contingencies should be specifically 

accounted for. This cost reflects the belief that project proponents should always count on 

the unexpected and prepare for such a contingency with extra funding. Contingencies 

often are applied as a percentage of total project costs. The percentage may increase as a 

function of any combination of factors, such as project complexity and duration; use of 

relatively new techniques, equipment, or materials; and number of project partners and 

required degree of coordination. Guidance on developing contingency allocations is 

provided in a number of cost estimating references (e.g., U.S. ACE and U.S. EPA, 2000). 

` Operations and maintenance: Most habitat restoration projects require some level of 

ongoing effort to ensure anticipated benefits are realized. For some projects these 

expenses can represent a significant share of lifetime project costs and may be critical to 

the project’s success (e.g., dredging a waterway to maintain tidal exchange). Because 

these expenditures are incurred following the “completion” of most of the initial 

restoration work and may require a separate source of funding they should be specifically 

and separately accounted for in a cost estimate. 
56

` Monitoring: Monitoring activities may be a critical element of adaptive management of a 

project and will generally be required to document, qualitatively and/or quantitatively, 

project performance. Because these expenditures will occur in future periods after project 

“completion,” and may require separate funding, they should be specifically and 

separately accounted for in a cost estimate. 

` Oversight and administration: The project proponent cannot effectively implement a 

habitat restoration project without providing some level of oversight and administration. 

The resources in terms of labor and any supplies that are required as part of this effort 

need to be accounted for. 

The value of this cost categorization approach is that key elements of cost estimates are explicit, 

which helps ensure that all costs are accounted for. A full accounting of costs is critical to project 

success. 

I.3.2 Evaluating cost estimates for habitat restoration projects 

To ensure that all cost elements are included in a cost estimate for a given project, a number of 

key questions should be addressed: 

` Is the project narrative consistent with the available cost information? 

Relevance: If the cost estimate is inconsistent with the project narrative, it is likely to 

underestimate true project costs. For example, if a project description notes the need for 

significant habitat re-grading or re-contouring the cost estimate should include costs for actions 

and equipment consistent with this activity (e.g., soil excavation and/or removal). 

` Are donated or discounted goods and/or services accounted for in the cost information? 

Relevance: In many cost estimates there is no accounting of goods and services that were 

donated or provided at discount. This is required for an accurate reflection of the actual resource 

commitments required to achieve the project outcomes. Failing to account for these donated 

goods or services would result in an underestimate of cost if similar discounts or donations 

cannot be obtained for other projects. For example, many kelp and sub-aquatic vegetation 

restoration projects rely on scuba divers to harvest and transplant the relevant vegetation. This 

labor is critical to project implementation, and is often donated by individuals or organizations 

(e.g., dive clubs). In developing a comprehensive cost estimate, the fair market value of such 

volunteer services should be included. 

` Do the available costs reflect only the funding commitment from one project partner? 

Relevance: Many habitat restoration projects are undertaken as cooperative efforts by 

combinations of public agencies (e.g., CDFG, NOAA) and private individuals and organizations. 

This can create a situation where project summaries describe the full range of restoration 

activities but the costs reflect only the funding commitment from the partner providing the 

information. Where this occurs, cost estimates will understate the actual project costs. 
57

` Have prior expenditures and resource commitments associated with habitat acquisitionaccess and project permitting and design been accounted for? 

Relevance: Costs and resource commitments associated with habitat acquisition-access and 

project permitting and design can represent a significant share of the total anticipated/realized 

costs for a restoration project. At the same time, these expenses and resource commitments may 

be incurred well in advance of the final project implementation. As a result, these costs may be 

omitted from cost estimates that address remaining actions or summaries that start from the point 

of physical work to restore the habitat. Failure to account for these prior period expenditures will 

result in an artificially low project cost estimate. 

` Have anticipated future operations and maintenance expenditures and monitoring costs 

been accounted for? 

Relevance: Because these expenditures will be incurred in the future, after the restoration project 

has been “completed,” they may be omitted from some project cost estimates. This omission will 

understate the true project costs and, in some cases, may omit consideration of costs that are 

crucial for ongoing project success and the ability of the project to meet stated goals. This issue 

could also arise if there is an anticipated transfer of property rights following the initial project 

completion that would involve these future costs being borne by an agency or organization that is 

not part of the project implementation team. 

` Does the cost estimate incorporate contingency costs? 

Relevance: Incorporating funding to account for unexpected events or issues is a well-recognized 

element of developing a realistic cost estimate. Provision for contingencies may represent a 

significant portion of the total cost estimate, especially for more complex projects. A cost 

summary associated with detailed construction plans that specify quantities of materials and 

labor, with associated unit costs, may omit a line item for contingencies as all costs are already 

incurred. Project cost estimates that do not incorporate contingency funding in the total will 

understate anticipated costs compared to a comprehensive cost estimate. 

` Are costs for project administration and oversight accounted for? 

Relevance: The costs associated with the labor and any associated goods and services required to 

administer and oversee a project’s development and implementation need to be accounted for to 

avoid understating true project costs. However, these costs are frequently omitted, especially 

when existing personnel from public agencies provide these services. In these cases, a common 

view is that these staff are just completing part of their recognized job assignment. The 

importance of accounting for these resources is clear, though, when considering the costs 

associate with private compared to public sector projects.
58

` Do project costs involve non-habitat related expenditures or expenses notable because 

they are unlikely to be frequently encountered? 

It is commonly the case that a project narrative provides some description of project goals and 

implementation activities, but only provides a simplified cost estimate, such as “the project will 

restore X acres of habitat for Y dollars.” In such cases it will be difficult, if not impossible, to 

assess the completeness of the cost estimate without developing additional information. 

The most effective means of addressing omitted costs from the list above is to contact the current 

project manager. Often these discussions will clarify what is not included in the initial cost 

estimate. Having identified the omission, additional information can be elicited from the project 

manager, either actual cost estimates or approaches for developing estimates. 

I.3.3 Sources of California aquatic habitat restoration project summaries 

Table I.1 provides a summary of databases that contain information for proposed and completed 

nearshore habitat restoration projects in California. 

As noted in Table I.1, several of these databases provide cost information or include a specific 

field where cost information can be included. In general, these cost summaries present values 

with little documentation or listing of sources. Therefore, we recommend that, in general, all 

such cost estimates be treated as likely underestimates of true project costs until more detail is 

obtained. These inventories generally provide contact information that should facilitate the next 

step of contacting a knowledgeable project manager to help better understand the completeness 

of the cost information presented. For projects of interest that lack cost estimates the project 

contact information can be used to begin efforts to develop this information. 

An additional benefit of these databases is that they can be used to help identify potential 

restoration projects in a specific area or individuals in an area that may be familiar with certain 

types of habitat restoration projects. Such individuals may also suggest additional information 

sources. 

I.3.4 Combining cost information from multiple restoration projects 

There is often interest in knowing what an “average” cost for restoring a unit (e.g., an acre) of 

degraded habitat may be. Extreme caution should be used in developing and applying such 

estimates. 
59

Table I.1. Summary of identified aquatic habitat restoration project databases for California Database name 

Internet location 

(home) General description Information available Note

California Environmental Information Catalog (CEIC) 

http://gis.ca.gov/catalog/ 

Allows users to design queries to obtain links to data sources and collections of interest. 

CEIC summary form includes the following fields among others: Title Abstract Time period Purpose Date updated Data contact Links can take you directly to more detailed information from the listed organization 

To access the query options for from the homepage do the follo1. Select By Resource Type in tData on the left of the page. 2. At next page select By Keywo

on the left. 3. At next page select Natural Roptions for types of natural resoinclude: Aquatic resources Energy resources Fishery resources Forest resources Genetic resources Mineral resources Natural resource management Nonrenewable natural resourceRangelands Recreation Renewable natural resources Soils Water resources Wildlife resources.4. Click on resource of interest descriptors may appear to help links to datasets of interest.Notable project links include acSan Francisco Joint Venture Pr
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Table I.1. Summary of identified aquatic habitat restoration project databases for California (cont.) Database name 

Internet location 

(home) General description Information available Notes 

California Ecological Restoration Projects Inventory (CERPI) – Natural Resource Projects Inventory (NRPI) 

http://www.ice.ucdavis.edu/nrpi/ 

Provides a searchable database with links to over 6,000 natural resource-related projects in California. Database has links to information in the CEIC, Geofinder, California Digital Atlas, and Google Maps. 

Detailed project summary forms from database searches provide information on the following areas among others: Project name Purpose Abstract Time period Funding sources and amount Purpose Project size and methods Date updated Data contact 

Searchable field categories presenhomepage include: Title Purpose Abstract Funding program Contact person Participant Project date Project type County Resource issue Water quality constituents Habitat Species Best Management Practices (BMPControl method Multiple field query (full text searDrop down lists and follow-up quselected, are used to help refine thof habitat descriptors potentially rproposals include Estuarine, MariWetland.The response to searches generally describing the project purpose and project summary. 
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Table I.1. Summary of identified aquatic habitat restoration project databases for California (cont.) Database name 

Internet location 

(home) General description Information available Notes 

CALFED: Ecosystem Restoration Program Project Database 

http://www.delta.dfg.ca.gov/erpin/dbase_default.asp 

See Notes field. See Notes field. Website currently under construct

information can also be generated Restoration Program Project Locahttp://www.delta.dfg.ca.gov/erpinallows for queries to select types omapped with information that can map icons that are generated for th
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Table I.1. Summary of identified aquatic habitat restoration project databases for California (cont.) Database name 

Internet location 

(home) General description Information available N

California Habitat Restoration Project Database (CHRPD) 

http://www.calfish.org/DesktopDefault.aspx 

“The CHRPD currently contains data from the CDFG’s Fisheries Restoration Grants Program, the CALFED Ecosystem Restoration Program, the National Fish and Wildlife Foundation, the State Coastal Conservancy, the NOAA Restoration Center, the U.S. Fish and Wildlife Service, the California Conservation Corps, and the Cantara Trustee Council.” Quote from the CalFish website text that comes up after clicking on the Restoration Projects link on the left side of the homepage. 

The CalFish website describes the following information being available from the CHRPD: General project types included in the CHRPD Habitat improvement Watershed assessment and planning Watershed organization support Monitoring Land and water right acquisition Education Hatchery projects Data categories Data source(s) Project timeframe Project description Limiting factors addressed by the projectParticipants (including role and financial contribution) Funding sources Project costs Site-specific data: 

Site location 

Land cover Restoration goals Treatment details and quantities Post-project monitoring Land ownership Project performance measures Species affected Final analysis and final report References 

Requires using a mapping clicking on the link on thfor Fish Maps in the sectiMaps. 
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Table I.1. Summary of identified aquatic habitat restoration project databases for California (cont.) Database name 

Internet location 

(home) General description Information available N

National Estuaries Restoration Inventory 

https://neri.noaa.gov/index.htm 

Provides a listing of habitat restoration projects in various estuarine habitats by location around the United States. Search parameters can be defined to narrow the list of projects that are returned. 

In the most detailed project summary, the following information is available: Detailed project description and summaryProject contact information Summary of the habitat types and acreage restored Project benefits Project partners Project funding 

To search the inventory, fInventory link on the homBasic Search heading on projects (https://neri.noaabe used to search for relevwhich provides a search bhabitat type which pulls umenu of habitat types to cfor projects is made by hacan be sorted by state by in the table that is returneClicking on the project nareturned moves the user tthat initially presents an ea summary of the project project partners. Clicking of this summary for Full 

most detailed project sum

Bay Area Wetland Tracker 

http://www.wetlandtracker.org/ 

Provides a listing of wetland restoration projects in North and South San Francisco Bay. 

Accessing the links for the listed projects provides a more detailed summary with the following information: Latitude Longitude Mapped project area Reported project area Project type (e.g., restoration) Counties Land owner Project contacts Links to additional files 

From the homepage, click projects on the top right oidentified projects. Clickiproject will open a more information beyond the Nprovided in the list. 
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Table I.1. Summary of identified aquatic habitat restoration project databases for California (cont.) Database name 

Internet location 

(home) General description Information available N

Southern California Wetlands Recovery Project 

http://www.scwrp.org/work_plan.htm 

In the more detailed summaries project information includes: Date of last project update Project leads and contacts Project Description Estimated cost Summary of funding 

The Wetlands Recovery Pinformation on ongoing avarious levels of detail. Tsummary of completed prProject Descriptions undCompleted Projects on thFor a summary of ongoinfor Work Plan Project De

page in the section titled For a more detailed summthe link for WRP Informaof the homepage in the seAt the next page click on Completed Projects on thresulting drop down menu in the combined completedatabases appear. The Wetlands Recovery Pbetween the U.S. MexicaPoint Conception in the n
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Specifically, cost estimates from multiple projects should be combined only when the values 

reflect comprehensive estimates that, if appropriate, have been adjusted (i.e., discounted) to 

account for future expenditures. When combining cost estimates to develop summary measures 

care must also be taken in how the summary measure is calculated. For example, an average cost 

per acre of tidal wetland restoration can be calculated by dividing the sum of all estimated costs 

by the sum of all acres to be restored in the select project groups. Alternatively, an average cost 

for each project could be initially calculated and then an average of the results be calculated. 

Only in rare cases (i.e., when each project has the same average cost) will the results be the 

same. In addition, the range of unique opportunities, constraints, and requirements that are 

reflected in comprehensive cost estimates should produce a wide range of “average” costs across 

restoration projects focused on a specific habitat with a large enough sample. This variability 

should highlight the sensitivity of restoration costs to site-specific elements that can only be 

adequately accounted for when considering a potential project by conducting an initial 

assessment of the site. Finally, project proponents should realize cost estimates are only one 

component of determining cost effectiveness. In the case of restoration projects focused on 

improving the production of fish information on expected increases in production as a result of 

the project implementation is needed to calculate accurate measures of a project’s cost 

effectiveness. 
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1. The ETM method described in Steinbeck et al. (2007) is based on a model originally developed by Boreman et al. 

(1978, 1981) for Hudson River entrainment studies and later modified by MacCall et al. (1983) for power plants 

located on estuaries and open coasts. A similar model was developed by Barnthouse et al. (1979) to address 

impingement. Because local biologists consider California impingement losses to be insignificant, the HPF only 

evaluates entrainment losses. 

2. This approach can be modified by first calculating the area of a particular type of habitat in a SWA (e.g., rocky 

reefs based on aerial photos that identify kelp beds as for the HPF for the Diablo Canyon power plant). 

3. The HEP used what it described as a HEA analysis, but in many important respects it was incorrectly designed 

and implemented, invalidating the HEA results. 

4. In southern California, there is a history of restoring coastal wetlands or artificial reefs as mitigation for losses of 

soft-bottom species (Davis et al., 2006b). 

5. Note that in a document on the DCPP Bingham and Desvousges (2005) incorrectly referred to the HPF as the 

HRC. Bingham and Desvousges (2005) also incorrectly stated that the EPA rejected the HRC. In fact, EPA’s 

comments on the HRC in Response to Public Comment on 316(b) regulations (U.S. EPA, 2004b) clarified that HRC 

estimates of restoration costs are not benefits estimates. HRC costs are, however, relevant for cost-effectiveness 

analyses. 

6. Note that it is important to use location-specific data for a trophic modeling approach. For example, estimates of 

primary production for Spartina marshes on the U.S. East Coast may differ, perhaps significantly, from those for 

Salicornia marshes on the Pacific Coast. 

7. “Wholly disproportionate” was the phrase used in hearings for the Seabrook, New Hampshire facility to define a 

limit on reasonable BTA costs. 

8. Contingency costs are unlikely to appear in a costs summary for completed projects.